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83 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments
    ERISAFinal Rules (FR)Jul 1, 2016
    00 per request 110 per day, not to exceed 1,100 per request 147 per day, not to exceed 1,472 per request. EBSA Employee Retirement Income Security Act Section 502(c)(7)—Per day for each failure to provide notices of blackout periods and of right to divest employer securities—each statutory recipient a separate violatio…
  2. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    …. M1 has net unrecognized section 987 gain with respect to M1 QBU. M1 QBU sells property to M2 for €100 in year 1. (B) Analysis —( 1) In general. Under paragraph (j)(9) of this section, the sale of property is treated as a transfer of the property from M1 QBU to M1, followed by an exchange of the property for €100 dire…
  3. Treas. Reg. § 1.424-1(c)(4) — Definitions and special rules applicable to statutory options.
    IRCRegulationsJan 19, 2017
    …ample 1.On June 1, 2004, the X Corporation grants to E, an employee, a statutory option to purchase 100 shares of X Corporation stock at $100 per share, the fair market value of X Corporation stock on that date. On June 1, 2005, while employed by X Corporation, E exercises the option in full and pays X Corporation $10,…
  4. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023
    …apital basis pool attributable to the distribution. If Branch transferred the land with a basis of €100 to DC on December 31, year 3, its remaining capital basis pool of $100 would be attributable to the distribution, and the land would have a basis of $100 in the hands of DC. Because the land had a basis of €100 in th…
  5. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    he payment of $100,000 is made on January 1, 2020. X determines the present value of the payment using an interest rate of five percent for all years. (ii) The present value of $100,000 payable on January 1, 2020, determined using a five percent interest rate, is $82,270 as of December 31, 2015; $86,384 as of December …
  6. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    ficiency for the years in issue. Respondent determined that petitioner was liable for additional taxes of $499 and $5,215 for early distributions from her IRAs for 1999 and 2000, respectively. Respondent also determined that petitioner was liable for additions to tax under sections 6651(a)(1) and 6654(a), as set out ab…
  7. Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona…
    IRCNoticesModified Dec 22, 2008
    …erred compensation plan sponsored by Employer, Specified Employee has a legally binding right to a $100,000 payment of deferred compensation on the first day of the seventh month following Specified Employee’s separation from service. Specified Employee separates from service on November 15, 2008 so that the payment is…
  8. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  9. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  10. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    … 89 1,319 90 1,429 91 1,547 92 1,676 93 1,815 94 1,967 95 2,131 96 2,308 97 2,500 98 2,709 99 2,934 100 3,179 101 3,443 102 3,730 103 4,041 104 4,377 105 4,742 106 5,137 107 5,565 108 6,029 109 6,531 110 7,075 111 7,663 112 8,303 113 8,994 114 9,743 115 10,554 116 11,433 117 12,385 118 13,417 119 14,535 120 15,745 121 …
  11. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    … 89 1,404 90 1,521 91 1,648 92 1,784 93 1,932 94 2,094 95 2,268 96 2,457 97 2,661 98 2,884 99 3,124 100 3,385 101 3,666 102 3,971 103 4,302 104 4,660 105 5,049 106 5,469 107 5,925 108 6,418 109 6,953 110 7,532 111 8,157 112 8,839 113 9,575 114 10,373 115 11,236 116 12,171 117 13,186 118 14,284 119 15,474 120 16,762 121…
  12. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  13. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013★ strong match
    …e estimated amount for the years his tax statements stated that he worked 25% of his time at TORCH, 100% for the years after his retirement, and 25% for the years after the Fletchers sold TORCH. The following table shows Dr. Newlon's conclusions as to reasonable compensation for the Fletchers: [*16] Year Ms. Fletcher %…
  14. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001related by meaning
    claim to a pension plan contribution deduction on that ground forecloses her claim that she is entitled to an above-the-line Schedule C deduction for legal fees, rather than the itemized deduction subject to the 2percent limitation of section 67 that respondent allowed in the statutory notice. To give effect to all the…
  15. Treas. Reg. § 1.414(c)-2(e) — Two or more trades or businesses under common control.
    IRCRegulationsDec 30, 2024
    …nterest of at least one of the other organizations, ABC is treated as the owner of stock possessing 100 percent of the voting power and value of all classes of stock of X and of Y for purposes of paragraph (b)(1)(ii) of this section. Therefore, ABC is the common parent of a parent-subsidiary group of trades or business…
  16. 84 FR 213 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2019
    ERISAFinal Rules (FR)Jan 23, 2019
    672 81 727 82 787 83 854 84 925 85 1003 86 1,086 87 1,175 88 1,274 89 1,380 90 1,495 91 1,619 92 1,753 93 1,899 94 2,058 95 2,229 96 2,414 97 2,615 98 2,834 99 3,070 100 3,326 101 3,602 102 3,902 103 4,227 104 4,579 105 4,961 106 5,374 107 5,822 108 6,307 109 6,832 110 7,401 111 8,016 112 8,686 113 9,409 114 10,193 115…
  17. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    . See FPL Grp., Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994).…
  18. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  19. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  20. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.