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82 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  2. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973★ strong match
    …the fiscal year ended March 25, 1966, following the same system petitioner deducted a total of $202,696 for sick leave pay. This amount was composed of $204,446 actually paid as sick leave during the 1966 fiscal year plus $193,890 which petitioner would be required to pay during the ensuing fiscal year for previously a…
  3. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  4. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    inations that will enter into open negotiation, the annual burden would be 14,696 hours, with an annual equivalent cost estimate of $1.5 million.[253] The open negotiation notice must be sent within 30 business days beginning on the day the provider of air ambulance services receives an initial payment or a notice of d…
  5. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    -2503 at 95-2504, 95-1 USTC par. 50,280 (D. Md. 1995); see also Conway v. United States , supra ; cf. Wheeler v. Commissioner , T.C. Memo. 1993-561. 6 We observe that the definition of "qualified total distribution" set forth in section 402(a)(5)(E)(i)(II) incorporates the definition of "lump sum distribution" set fort…
  6. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019★ strong match
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  7. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …5971) Total: Total 20,078,016 81,756,286 90,848,839 1,660,214 119,169 11,082,746 238,339 Per-Entity 696 696 696 749 1,671 1,671 1,671 SBA: Threshold (in millions)
  8. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    ….67 2,753 0 0 Clerical workers prepare comparative analyses upon participant request 92,354 0.083 7,696 65.99 507,859 2.79 107,477 Clerical workers maintain recordkeeping 92,354 0.083 7,696 65.99 507,859 0 0 Total 92,374 15,492 1,027,620 107,477
  9. 77 FR 5454 — Modifications to Minimum Present Value Requirements for Partial Annuity Distribution Options Under Defined Benefit Pension Plans
    IRCProposed Rules (FR)Proposed Feb 3, 2012
    …ember 2012 segment rates would have been $1,000 × 12 × the deferred annuity factor of 6.558, or $78,696. The single sum payment actually available to Participant W under the provisions of Plan D is $10,000, which represents 12.71% of the single sum value of W's full accrued benefit ($10,000 ÷ $78,696 = 12.71%).
  10. 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…
  11. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  12. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008
    …61 275,87 1 4 275,871 25,000 250,871 21,070 271,94 1 5 271,941 25,000 246,941 20,755 267,69 6 6 267,696 25,000 242,696 20,416 263,11 2 7 263,112 25,000 238,112 20,049 258,16 1 8 258,161 25,000 233,161 19,653 252,81 4 9 252,814 25,000 227,814 19,225 247,03 9 10 247,039 25,000 222,039 18,763 240,80 2 11 240,802 25,000 21…
  13. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
  14. 90 FR 4192 — Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025
    …+ C) VFC Program 6,491 $568,473 $3,313 $571,786 VFCP Exemption 1,205 101,126 19,110 120,236 Total 7,696 669,600 22,423 692,023 In summary, the categories in the table below encompass the numbers for both the VFC Program and the amended class exemption: Type of Review: Revision of currently approved collection of inform…
  15. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …rdingly, the Department estimates that 44.6 million plan participants will receive the disclosures.[696] Additionally, the Department estimates that 67.8 million IRA owners will receive disclosures.[697] Of the 44.6 million plan participants, it is assumed that 3.9 percent, or 1.7 million plan participants would receiv…
  16. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  17. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
  18. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    …amount to terminated participants by December 31, 1994. During this period the SIP also made $1,589,696 in distributions to terminated participants out of cash otherwise available.
  19. 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).…
  20. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    …, which is equal to the $2,500,000 funding target, reduced by the sum of $2,450,000 of assets, $316,696 (the present value of the remaining installments with respect to the 2015 shortfall amortization base) and $113,116 (the present value of the remaining installments with respect to the 2015 funding waiver).(iii) The …