IRCCourt RulingsAug 12, 1998
…adhere to must be present. Rev. Rul. 73532, 1973-2 C.B. 128, extended the reasoning of Rev. Rul. 69-494,
supra
, to investments not involving employer securities.
9
Sec. 404(a)(1) of the Employee Retirement Income Security
Act of 1974 (ERISA), Pub. L. 93-406, 88 Stat. 877, provides as
follows:
Sec. 404.(a)(1) Subject t…
REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie… IRCProposed Rules (FR)Proposed Jul 5, 2005
…alent straight life annuity computed using the plan’s assumptions used for computing offsets is $54,494 per year, and the actuarially equivalent straight life annuity computed using the applicable interest rate and the applicable mortality table as of January 1, 2006, is $50,103 per year. Thus, N’s annual benefit attri…
87 FR 56912 — Initial Regulatory Flexibility Analysis for Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption) ERISAProposed Rules (FR)Proposed Sep 16, 2022
…viction QPAMs
165
Additional Requirement-Prohibited Misconduct QPAMs
536
Rule Familiarization Costs
494
494
494
First Year Total Estimated Annual Cost
728
3,089
893
Subsequent Years Total Estimated Annual Cost 1
0
2,361
165
Notes:
Only quantifiable costs are displayed.
Additionally, two individual exemption application…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1996-450
UNITED STATES TAX COURT
THEODORE SOURIS, P.C., A DISSOLVED CORPORATION,
AND THEODORE SOURIS, AS SUCCESSOR IN INTEREST
OF THEODORE SOURIS, P.C., Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 639-95. F…
87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption) ERISAProposed Rules (FR)Proposed Jul 27, 2022
…m/see.html,
Year: 6/01/21-5/31/22): ($381 * 0.4) + ($468 * 0.35) + ($676 * 0.15) + ($764 * 0.1) = $494. The total cost associated with reviewing past exemptions is then (2 applications * 3 hours * $494 outside legal professional rate) = $2,964 (rounded). Therefore, the total cost associated with the additional require…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016
................................................ 494
.08 Penalty of perjury statement ............................................................ 494 .09 Procedural Requirements Checklist . . .. . .. . .. . .. . .. . .. . ......................... 494
.10 Orphan Plan ... . .. . .. . .. . .. . .. . .. . .. . .. . .. . …
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…
85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020 ERISAFinal Rules (FR)Jan 15, 2020
…. § 1903.15(d)(1)
$132,598
$134,937.
§ 1903.15(d)(2)
$132,598
$134,937.
§ 1903.15(d)(3)
$13,260
$13,494.
§ 1903.15(d)(4)
$13,260
$13,494.
§ 1903.15(d)(5)
$13,260
$13,494.
§ 1903.15(d)(6)
$13,260
$13,494.
DEPARTMENT OF LABOR
Mine Safety and Health Administration
Title 30—Mineral Resources
PART 100—CRITERIA AND PROCEDURE…
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
IRCCourt RulingsJun 4, 1984
early premised to some extent on the principles set forth in Rev. Rul. 69-494, supra, and a number of the decisions specifically discussed the ruling. Central Motor Co. v. United States, supra, applies the exclusive benefit rule in the context of trust investments. In that case, the trustees of a profit-sharing trust l…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…external review, the cost burden for the clerical worker to maintain records is estimated to be $56,494 (12,275 × 5 minutes × $55.23).
Table 59—Annual Burden and Cost for IROs To Maintain Record of All Claims and Notices Starting in 2022
Year
Estimated number of
responses
Total annual burden
(hours)
Total
estimated
lab…
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 RulingsJun 18, 1959
…Taxes. 1,074.34 2,140.98
Contributions. 206.00
Depreciation. 73.61 515.70
Depletion. 119,689.38 131,494.22
Other deductions. 5,385.15 11,026.00
Total deductions. (133,370.64) (161,352.83)
Net income.-120,210.13 131,494.22
Depletion computation:
Total production (sales) 1,714,327.10 1,935,793.57
Share of profits (46Mi p…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
IRCCourt RulingsJan 22, 2025
…
explain ing how the 2009 NOL of $444,600 and a 2009 capital loss of
$182,344 ( as opposed to $ 206,494 as reflected on th e first document ) had
been generated . To that end, she stated therein that the former was due
to the foreclosures on the North Carolina properties that had cost bases
4
Statutory interest of $6,4…
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights ERISAFinal Rules (FR)Dec 1, 2022
…lans considering ESG factors when selecting investments
Review of Plan Investment Practices
$91,510,494
$0.00
$612.84
$0.00
Total
91,510,494
0.00
612.84
0.00
Plans holding corporate stock, directly or through ERISA-covered intermediaries
Review of Proxy Voting Practices
39,019,523
0.00
612.84
0.00
Update Proxy Voting P…
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 RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …