IRCCourt RulingsJul 31, 2000
…
Employee benefit programs -0- -0- -0- -0-
Other deductions (VEBA contribution) 480,901 -0- 209,869 296,056
Taxable income (loss) 3,664 (103,857) (23,325) (7,796)
Income tax 1,246 -0- -0- -0-
Alt. minimum tax -0- -0- -0- 20,531
It filed its 1992 Federal corporate income tax return untimely on
May 28, 1993.
Marlton is a…
ERISACourt RulingsAug 10, 2026
tation and application of the Plan.” J.A. 380; see also
J.A. 296 . And, while the plan names various fiduciaries with more specific responsibilities , it names the administrator as the fiduciary vested with “general administration of the Plan.”
J.A. 364. The plan does not name Fidelity as a fiduciary. See J.A. 364 – 68…
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…
ERISACourt RulingsAug 10, 2026
tation and application of the Plan.” J.A. 380; see also
J.A. 296 . And, while the plan names various fiduciaries with more specific responsibilities , it names the administrator as the fiduciary vested with “general administration of the Plan.”
J.A. 364. The plan does not name Fidelity as a fiduciary. See J.A. 364 – 68…
IRCCourt RulingsDec 18, 2012
1
BOA3886
FFB0488
FFB2740
Total
Deposits
$3,206
$28,531
$400,296
$157,654
$589,687
Less:
Transfers
between
accounts
(1,200)
(10,000)
(25,000)
(30,500) (66,700)
Nontaxable
items
-0-
-0-
-0-
(1,128)
(1,128)
Unreported
income
(2,000)
(5,520)
(15,000)
-0-
(22,520)
Miscellaneous
small
deposits
(6)
-0-
-0-
-0-
(6)
Rental
inc…
IRCCourt RulingsJan 14, 2013★ strong match
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…
83 FR 22387 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)May 15, 2018
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 296 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set
For plans with a valuation date
Immediate annuity rate
(percent)
Deferred annu…
IRCCourt RulingsJan 17, 2024related by meaning
ccord Grajales, 156
T.C. at 58– 59 ( same). Section 4973 does not appear in C hapter 68,
Subchapter A , captioned “Additions to the Tax and Additional Amounts .” T he exaction it imposes is therefore not an “a dditional
amount” within the meaning of section 6751(c).
To implement the foregoing,
An order will be issued g…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
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…
IRCCourt RulingsAug 16, 2005
ibed guidelines in Rev. Proc. 2003-61, 2003-2 C.B. 296,
8
to
- 18 -
8
(...continued)
1 C.B. 447, and is effective either for requests for relief filed on or after Nov. 1, 2003, or for requests for which no
preliminary determination letter was issued as of Nov. 1, 2003.
In the present case, the request for relief was st…
IRCCourt RulingsJan 31, 2008
, Fam . Law sec . 8205 by Acts 1984, ch . 296, secs . 1 and 2),27 did not authoriz e
Maryland courts to transfer ownership of an interest in a pension plan as part of a divorce settlement . See generally Klingenberg
v . Klingenberg , 675 A .2d 551, 555-556 (Md . 1996) . It was no t
until 1986 that the legislature of th…
IRCCourt RulingsAug 16, 2005
…minary determination letter was
issued on Dec. 19, 2003; therefore, Rev. Proc. 2003-61, 2003-2
C.B. 296, is applicable in the present situation.
SEC. 6015(f). Equitable Relief.--Under procedures
prescribed by the Secretary, if-–
(1) taking into account all the facts and
circumstances, it is inequitable to hold the
indi…
IRCCourt RulingsOct 17, 1995
…0- -0Miscellaneous -0- 14.00 -0- 14.00
Pool service -0- 629.50 -0- 629.50
12
Depreciation 14,969.00
296.00
296.00
-0-
Total 28,939.91
7,147.83
4,591.86
2,555.97
The Charleston Property: 1989
IRCCourt RulingsJun 18, 1997related by meaning
r personal injuries or
sickness to the extent such amounts are (A) attributable to
- 11 -
7
Former sec. 105(d) provided a limited exclusion from gross income for amounts received in lieu of wages prior to attaining
age 65 by completely disabled persons retired on disability.
Sec. 105(d) was repealed by sec. 122(b) of t…
IRCCourt RulingsJun 17, 1997
…of officers 176,300 274,600 451,200 437,892 239,200
Salaries & wages 49,649 74,655 37,767 52,014 53,296
Pension, profit-shar. plans 40,000 8,500 43,261 152,464 150,696
Employee benefit programs-0-100,000 56,739-0 - - 0 -
Taxable income 69,279 478,098 95,100 231,648 101,792
- 41 -
Of the reported compensation, Robert Bo…
IRCCourt RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
IRCCourt RulingsMar 20, 1997★ strong match
series of substantially
equal periodic payments made for life; (5) to an employee after
separation from service after attainment of age 55; or (6) as dividends paid with respect to corporate stock described in
section 404(k).
- 14 -
6
Sec. 4975 imposes two levels of excise tax on "any
disqualified person who participa…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
…-1
2,594,856
2,594,856
763
763
PTE 77-4
0
0
0
0
PTE 80-83
0
0
0
0
PTE 83-1
0
0
0
0
PTE 1986-128
444,296
444,296
242
242
Total
247,970,380
212,694,976
22,459
6,657
Note:
The sum of the columns may not sum to total due to rounding.
Preliminary Assumptions and Cost Estimate Inputs
The Department also assumes affected enti…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …