Brief Case

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to 67 T.C. 736 (not yet in the library — opens the official source)
80 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    10,592,106 132,541,874 C. Value of assets (beginning of year) a. VEBA --- 30,736,554 30,176,217 39,940,676 b. 401(h) --- 1,125,467 1,172,269 7,598,653 c. Total --- 31,862,021 31,348,486 47,539,329 D. Nondeductible contribution from prior years (O from prior year) --- 22,034,781 14,394,743 14,426,384 E. Net value of ass…
  2. 88 FR 44596 — Short-Term, Limited-Duration Insurance; Independent, Noncoordinated Excepted Benefits Coverage; Level-Funded Plan Arrangements; and Tax Treatment of Certain Ac…
    IRCProposed Rules (FR)Proposed Jul 12, 2023
    l not affect the remainder thereof. * * * * * 9. Section 2590.736 is revised to read as follows: ( printed page 44655) § 2590.736 Applicability dates. Sections 2590.701-1 through 2590.701-8 and 2590.731 through 2590.736 are applicable for plan years beginning on or after July 1, 2005. Until the applicability dates set …
  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. Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c…
    IRCNoticesMay 6, 2024
    agraph (c)(4) and shall not affect the remainder thereof. * * * * * 8. Section 2590.736 is revised to read as follows: § 2590.736 Applicability dates. Sections 2590.701–1 through 2590.701–8 and 2590.731 through 2590.736 are applicable for plan years beginning on or after July 1, 2005. Notwithstanding the previous sente…
  5. 89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
    IRCFinal Rules (FR)Apr 3, 2024
    …nder of this paragraph (c)(4) and shall not affect the remainder thereof. * * * * * 8. Section 2590.736 is revised to read as follows: § 2590.736 Applicability dates. Sections 2590.701-1 through 2590.701-8 and 2590.731 through 2590.736 are applicable for plan years beginning on or after July 1, 2005. Notwithstanding th…
  6. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …0 1 51.3 48.7 44.8 60,610,921 20,656,573 5,639,871 47,024,610 133,931,975 2 57.3 42.7 38.8 0 0 0 40,736,877 40,736,877 3 60.2 39.8 35.9 0 0 0 37,677,581 37,677,581 4 61.7 38.3 34.4 0 0 0 36,189,080 36,189,080 5 62.3 37.7 33.8 0 0 0 35,464,850 35,464,850 6 62.7 37.3 33.4 0 0 0 35,112,476 35,112,476 7 62.8 37.2 33.3 0 0 …
  7. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    T .C . Memo . 2007-292 UNITED STATES TAX COUR T HUBERT JOUBERT, Petitioner V . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 8769-06 . Filed September 24, 2007 . P failed to file a Federal income tax return for 2002 . R determined a deficiency and asserted in the notic e deficiency, the answer, and the pret…
  8. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    …islative history, “but its language could scarcely be more explicit,” Bob Jones Univ. , 416 U.S. at 736. The Supreme Court has interpreted the principal purpose of the AIA as the “protection of the Government’s need to assess and collect taxes as expeditiously as possible with a minimum of preenforcement judicial inter…
  9. 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…
  10. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  11. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997
    …elies on three Tax Court cases and one Second Circuit case, Gilford v. Commissioner , 201 F.2d 735, 736 (2d Cir. 1953), affg. a Memorandum Opinion of this Court, and attempts to distinguish Grier from this case. In Gilford , the taxpayer inherited fractional interests in several buildings in the 700 block of Third Aven…
  12. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    …t the law firm, petitioner has not shown that he is entitled to a loss deduction in 1991. Section 1.736-1(a)(1)(ii), Income Tax Regs., provides: A partner retires when he ceases to be a partner under local law. However, for purposes of subchapter K, chapter 1 of the Code, a retired partner or a deceased pa rtner's succ…
  13. 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…
  14. 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…
  15. 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 …
  16. 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-…
  17. 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…
  18. 83 FR 38212 — Short-Term, Limited-Duration Insurance
    IRCFinal Rules (FR)Aug 3, 2018
    CFR 2590.736, 45 CFR 146.125, and 45 CFR 148.102. Therefore, the Departments proposed conforming amendments to those rules as part of this rulemaking. The Departments also proposed a technical update in 26 CFR 54.9833-1, 29 CFR 2590.736, and 45 CFR 146.125 to delete the reference to the applicability date for amendment…
  19. IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
  20. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…