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89 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …,000 deduction for accrued contributions owed the Trust. N.L. Booth's 1990 tax return claimed a $56,739 deduction for accrued contributions owed the Trust. On February 14, 1992, N.L. Booth paid Firstar Metropolitan Bank & Trust (Firstar) $55,000 of this amount; N.L. Booth never paid the remaining $1,739. Generally, the…
  3. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    … disclosures is estimated as: (44,593,228 plan participants receiving investment advice × 3.9%) ≉ 1,739,136 paper disclosures. Back to Citation 699.  The cost is estimated as: (1,739,136 paper disclosures × 2 pages) × $0.05 ≉ $173,914. Back to Citation 700.  This is estimated as: 67,781,000 IRA owners × 28.2% ≉ 19,114,…
  4. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    ersion, the Cgroup term policy’s conversion credit balance was $78,672.63, and - 45 - $74,739 of that amount ($78,672.63 x 95%) was transferred to the C-group conversion UL policy for potential earning. Dr. McManus will earn these credits in 120 equal monthly installments, beginning October 1996. The conversion credit …
  5. 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…
  6. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …es is entitled to business expense deductions for meals and entertainment expenses of $2,199 and $4,739 for 2004 and 2005, respectively, and travel expenses of $53,707 for 2005; (4) whether petitioner is liable for additions to tax under section 6651(a)(1) for failure to file Forms 5329, Additional Taxes on Qualified P…
  7. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    ioner's retirement distribution's being taxed twice. We think petitioners' contention is meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended by Congress. E.g., Maass v. Higgins , 312 U.S. 443, 449 (1941); United States v. Supplee-Biddle Hardware …
  8. Rev. Proc. 2005-76 — Retroactive payment of benefits; multiemployer plan; discretionary relief; extension. This procedure extends the date by which certain qualified retirement pla…
    IRCRevenue ProceduresDec 12, 2005
    …B. 991, relating to the Supreme Court decision in Central Laborers’ Pension Fund v. Heinz, 541 U.S. 739 (2004). SECTION 2. BACKGROUND
  9. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    … -- -- -- F TC33D Equipment-- Krom. 9/29/2004 14,500 14,500 -- -- -- -- -- E GPS System 10/7/2004 1,739 1,739 -- -- -- -- -- E BA463 2005 Mustang 11/20/2004 28,617 -- -- 2,960 4,700 2,850 1,675 E Equipment--Sears 2/26/2005 3,880 3,880 -- -- -- D BA201 2001 Mustang 5/6/2005 11,500 800 -- 2,140 3,424 2,054 1,233 E Comput…
  10. 143 T.C. No. 21 — Key Lime Investments, Inc. v. Commissioner
    IRCCourt RulingsNov 26, 2014
    …alification of a retirement plan. See Tamko Asphalt Prods., Inc. v. Commissioner, 658 F.2d 735, 738-739 (10th Cir. 1981), affg. 71 T.C. 824 (1979); H. Rept. 93-807, at 108 (1974), 1974-3 C.B. (Supp.) 236, 343; S. Rept. 93-383, at 114 (1973), 1974-3 C.B. (Supp.) 80, 193; see also Wenzel v. Commissioner, * * * [707 F.2d …
  11. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  12. 91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information
    PBGCProposed Rules (FR)Proposed Jul 21, 2026
    …sets the maximum penalty assessed under part 4071 of PBGC's regulation after January 8, 2025, at $2,739 per day of delinquency.[5] Section 4302 of ERISA authorizes PBGC to assess a civil penalty for failure to provide a notice as required by subtitle E of title IV, which provides the notice requirements unique to multi…
  13. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
  14. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    ic employees, (2) the plan would pay her a taxable annuity after she reaches age 60, (3) the plan has no survivor benefits, and (4) she would lose all benefits under the plan if she stopped contributing to it. . The record includes a summary of a tax convention signed by representatives of France and the United States …
  15. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014
    …ment." Petitioner's reliance.on Lofaren Trucking Serv., Inc. v. United States, 508 F. Supp. 2d 734, 739 (D. Minn. 2007), is misplaced. In Lofgren the Appeals officer erroneously determined that 2006 first quarter employment taxes were "new" tax debts incurred while a proposal was pending, when in fact, the taxpayer had…
  16. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    Internal Revenue Code . Accordingly, petitioner is liable for the section 6662 penalty . In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is i 6 - imposed upon such distributions unless the distributions meet the requirements of one of the exce…
  17. T.C. Summary Opinion 2002-52 — Daniel R. & Margaret J. Kallmyer v. Commissioner
    IRCCourt RulingsMay 9, 2002related by meaning
    ven report the distributions. the clear intent of Congress to prevent voluntary withdrawals, we decided that the penalty was inapplicable. Id. at 291. Petitioners’ reliance on Larotonda v. Commissioner , supra , is misplaced. Here, respondent did not levy on the retirement accounts. Petitioners made voluntary withdrawa…
  18. 87 FR 26806 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or a Term of Years, and Remainder or Reversionary Interests
    IRCProposed Rules (FR)Proposed May 5, 2022
    …ty of $52,910.48 per year payable for 13 years or until the prior death of a person aged 60 is $480,739.33 ($52,910.48 × 9.0859). Based on the calculations of paragraph (b)(2)(v)(E)( 6) of this section, the present value of an annuity of $47,089.52 per year payable for 14 years or until the prior death of a person aged…
  19. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
  20. 86 FR 68560 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 3, 2021
    …ter than— From— To— 2023 691 691 2,919 2,919 2024 706 706 2,984 2,984 2025 723 723 3,052 3,052 2026 739 739 3,122 3,122 2027 756 756 3,194 3,194 2028 774 774 3,268 3,268 2029 791 791 3,343 3,343 2030 810 810 3,420 3,420 2031 828 828 3,498 3,498 ( printed page 68562) 2032 or later 847 847 3,579 3,579 1  Applicable table…