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72 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    6.7 prescription fills for those participants, suggesting an average prescription cost of $181 for combined insurer and participant expenditures.[313] Given an estimate of 89.4 million participants in self and level-funded group health plans and assuming a similar utilization and cost of prescription drugs, the Departm…
  2. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …nt 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 of 2002 Safe Harbor Notic…
  3. 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…
  4. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …nt glide paths. The authors modified these target date funds to include private equity investments.[181]
  5. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026
    …istleblower 14376- 16W v. Commissioner, T.C. Memo. 2024-22, at *27, supplementing T.C . Memo. 2017- 181 ; see Kasper v. Commissioner, 150 T.C. 8, 20 – 23 (2018). We do not substitute our judgment for that of the agency but instead examine whether its determination was “ within the bounds of reasoned decisionmaking. ” S…
  6. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …our), 50 hours from a Business Analyst (at $120 per hour), and 36 hours from a DevOps Engineer (at $181 per hour) to complete this work. As shown in Table 23, this results in a total estimated burden of 576 hours per issuer or TPA, with an associated cost of approximately $84,406. For all 1,580 issuers and TPAs, as sho…
  7. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …to keep the company afloat. As a result, petitioner husband (on behalf of BJW) paid interest of $28,181. For 2011 BJW filed a partnership return, and petitioners reported a nonpassive loss from BJW on a Schedule E, Supplemental Income and Loss, for that year. Petitioners reported BJW's income and expenses on Schedules …
  8. T.C. Memo. 2017-139 — Louelia Salomon Frias & Mervyngil Salomon v. Commissioner
    IRCCourt RulingsJul 11, 2017★ strong match
    …ved paychecks from Glen Island on the following dates in the following amounts: August 10, 2012, $2,181; August 24, 2012, $2,181; September 7, 2012, $2,181; and October 19, 2012, $2,328. Mrs. Frias received earnings statements with her paychecks that included information about her pay, such as what deductions were take…
  9. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
  10. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997★ strong match
    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 …
  11. Treas. Reg. § 1.436-1(g)(6) — Limits on benefits and benefit accruals under single employer defined benefit plans.
    IRCRegulationsSep 9, 2016
    …by $350,000 to reflect the amendment results in an inclusive presumed adjusted funding target of $3,181,325 and would result in a presumed AFTAP of 73.87% (that is, the interim value of adjusted plan assets as of the valuation date of $2,350,000 divided by the inclusive presumed adjusted funding target of $3,181,325).(…
  12. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …NOTICE OF MERGER, CONSOLIDATION, ETC.? 180 .01 Scope 180 .02 Forms 180 .03 Supplemental information 181 .04 Compliance with Title IV of ERISA 181 .05 Termination prior to time for amending for change in law 181 .06 Restatement not required for terminating plan 181 SECTION 16. WHAT ARE THE DETERMINATION LETTER FILING PR…
  13. 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…
  14. 89 FR 85750 — Enhancing Coverage of Preventive Services Under the Affordable Care Act
    IRCProposed Rules (FR)Proposed Oct 28, 2024
    the covered population (approximately 181.4 million individuals) times a $316 reduction in out-of-pocket costs = $768.7 million. Back to Citation 196.  Approximately $768.7 million in new plan costs divided across 181.4 million covered individuals = $4.24 in annual premiums. Of the 181.4 million covered individuals, th…
  15. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
  16. 84 FR 37508 — Definition of “Employer” Under Section 3(5) of ERISA-Association Retirement Plans and Other Multiple-Employer Plans
    ERISAFinal Rules (FR)Jul 31, 2019
    …ly 4.4 million total participants, 3.7 million of whom are active participants. DC MEPs hold about $181 billion in assets.[71] Table 2—Current Statistics on MEPs   Number of MEPs Total participants Active participants Total assets MEP DC Plans 4,630 4.4 million 3.7 million $181 billion. As a share of all ERISA DC plans…
  17. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    … 180 .08 Interested party notification and comment 180 .09 Contrary authority must be distinguished 181 .10 Employer/employee relationship 181 .11 Incomplete applications 181 .12 Effect of failure to disclose material fact 182 .13 Where to file requests 182 .14 Submission of related plans 182 .15 Withdrawal of requests…
  18. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    itioner and his wife owned 100 percent of the Garrahan Agency, and since petitioner is a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G). 3. Conclusion The Garrahan Agency is a disqualified person under section 4975(e)(2), and thus it and petitio…
  19. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  20. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…