PBGCProposed Rules (FR)Proposed Oct 13, 2020
EFFECTIVE DATE OF THE FINAL RULE] records under:
(1) Section 552(b)(2) of FOIA, dealing in general with internal agency personnel rules and practices; (2) Section 552(b)(4) of FOIA, dealing in general with trade secrets and commercial and financial information;
(3) Section 552(b)(5) of FOIA, dealing in general with int…
PBGCFinal Rules (FR)Jul 25, 2022
ich include as of August 24, 2022 records under:
(1) Section 552(b)(2) of FOIA, dealing in general with internal agency personnel rules and practices; (2) Section 552(b)(4) of FOIA, dealing in general with trade secrets and commercial and financial information;
(3) Section 552(b)(5) of FOIA, dealing in general with int…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…cost
Total
hours
Equivalent
cost
(A) (B)
(C)
(A × B)
(A × B × C)
Rule Review (Service Providers)
3552 Service Providers
4
$181.06
14,208
$2,572,500
Rule Review (In-House)
70,322 = 703,224 Small Plans × 10% Not Using a Service Provider
4
181.06
281,290
50,930,295
Total
295,498
53,502,795
Table 19—Cost for Preparation …
IRCCourt RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
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…
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…
PBGCFinal Rules (FR)Jun 13, 2017
…e) of this section, no charge for searching (or in the case of a requester described under 5 U.S.C. 552(a)(4)(A)(ii)(II), for duplication) will be assessed if PBGC has failed to comply with any time limit under 5 U.S.C. 552(a)(6).”
b. Add paragraph (e).
The addition reads as follows:
§ 4901.31
Charges for services.
* *…
PBGCRegulationsAug 24, 2022
(a) (a) In general. Pursuant to the provisions of section 552 of FOIA, as amended, PBGC will assess charges to cover the direct costs of searching for, reviewing, and/or duplicating records requested under FOIA, except where the charges are limited or waived under paragraph (b) or (d) of this section, according to the …
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
PBGCRegulationsAug 24, 2022
…e records exempted from FOIA, which include as of August 24, 2022 records under:
(b)(1) (1) Section 552(b)(2) of FOIA, dealing in general with internal agency personnel rules and practices;
(b)(2) (2) Section 552(b)(4) of FOIA, dealing in general with trade secrets and commercial and financial information;
(b)(3) (3) S…
IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
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…
76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Aug 22, 2011related by meaning
Form 886-A,Explanation of Items);
Form 870,
Waiver of Restriction on Assessments and Collection of Deficiency in Tax and Acceptance of Overassessment; notices of proposed deficiency that allow the taxpayer an opportunity for review in the Office of Appeals (30-day letters); notices pursuant to section 6213(b) (mathemat…
IRCCourt RulingsJul 13, 2006
…uring the year 2002, petitioner, as an employee and a
participant in the pension plan, withdrew $67,552 .64 from the
plan, the proceeds of which were to fund her daughter's higher
education expenses .
On her Federal income tax return for 2002, petitioner
reported the entire amount of the pension plan withdrawal as
inco…
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…
IRCCourt RulingsMar 9, 2011related by meaning
ities. Classification of the
transaction as a prohibited transaction under section
408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is
subject to a 10-percent additional tax. See secs. 72(t),
408(e) (2) (]B). In cases where the Service att…
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
IRCProposed Rules (FR)Proposed Oct 31, 2023
…tinues to read as follows:
Authority:
80 Stat. 379; sec. 3, 60 Stat. 238, as amended; 5 U.S.C. 201, 552.
2. Add subpart A before § 323.1;
3. Revise the first sentence of § 323.1; and
4. Add subpart B after § 323.5.
The additions and revision read as follows:
PART 323—DISCLOSURE OF RECORDS
Authority:
80 Stat. 379; sec. …
PBGCCode / StatuteJan 6, 2025
…, exempt from disclosure pursuant to subparagraph (B) shall be exempt from disclosure under section 552(b) of title 5. For purposes of such section 552, this subparagraph shall be considered a statute described in subsection (b)(3) of such section 552.
IRCCourt RulingsJan 3, 2011related by meaning
s, earnings, and reasonable charges) pursuant
tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not :
rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant
to Rev. Proc . 2005-25, lsupra.
Held, further, P must include in his gross income
the excess contributiorls pursuan…