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…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…ed, and the broader context of the statute as a
whole. E state of Cowa rt v. Nicklos Drilling Co.
, 505 U.S. 469
(1992); M cCarthy v. Bronson
, 50 0 U.S. 136, 139 (1991). In
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…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…nmental plans with more than 500 participants that will conduct the comparative analysis themselves
505
505
Non-Federal governmental plans with more than 500 participants that will initially receive generic comparative analyses from TPAs or service providers and will then customize it
2,906
2,906
5.1. Issuers, TPAs, an…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…the amount of civil money penalty assessed against a provider or facility), and proposed 45 CFR 150.505 and 150.515 (which describe notices sent by CMS to responsible entities regarding potential violations and civil money penalties against a provider or facility). HHS proposes to make a similar conforming amendment to…
Notice 2007-84 — Post-retirement medical and life insurance benefits; nondiscrimination; welfare benefit funds. This notice alerts taxpayers that the tax treatment of trusts pr… IRCNoticesNov 5, 2007
st meet the nondiscrimination requirements of § 505(b) with respect to those benefits (even if those requirements do not otherwise apply to the plan). A plan meets the nondiscrimination requirements of § 505(b) only if (i) each class of benefits under the plan is provided under a classification of employees which is se…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…e reasonableness of a contract or arrangement. This proposed rule is under the authority of section 505 of ERISA, as well as both section 408(b)(2)(A) and section 408(b)(2)(B) of ERISA, as follows. The Department proposes to regulate entities providing pharmacy benefit management services, identified in paragraph (c)(1…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
PLR 200210025 — Qualified Asset Account; Limitations on Additions to Account (See Also 419.00-00|et. seq.) IRCPrivate Letter RulingsMar 8, 2002
…vided to a key employee be paid only from a separate
account established for that employee.
Section 505 of the Code provides for additional requirements that must be met
by an organization described in section 501(c)(9) or (20) that is part of a plan. Section
505(b) provides, in pertinent part, that the coverage of a p…
IRCCourt RulingsJul 5, 1983related by meaning
the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
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 RulingsMar 27, 1989related by meaning
983). They are among the clearest and most central requirements for favorable tax treatment and cannot be disregarded — deliberately or inadvertently. The amounts in question here ($80,490 and $6,715) were not de minimis, and in a quantitative sense they were material. The error occurred in more than one year, and occu…
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…
Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona… IRCNoticesModified Dec 22, 2008
…m AFR for July 2010 is 4.0%. Employer notifies Employee of the error and Employee pays Employer $10,505.73 on October 1, 2011, consisting of the $10,000 erroneous payment plus $505.73 interest.[2] The deferral is treated as made in accordance with the terms of the plan under this § V.B. For 2010, the $10,000 payment is…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…this regulation with safe harbors. The Department has clear statutory authority under ERISA section 505 to promulgate safe harbors, including safe harbors regarding the fiduciary duty of prudence (such as, for example, the selection of annuity providers under 29 CFR 2550.404a-4).
Cf. McNeil
v.
Time Ins. Co.,
205 F.3d 1…
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…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026
…he labor and benefits for the work performed related to overseeing the EA SEE is projected to be $3,505,101 in total over FYs 2026 through 2028. In addition to labor and benefits and overhead expenses, the IRS projects incurring travel, training, and supplies costs of $16,182.82 in each of FYs 2026 through 2028. The to…
ERISAProposed Rules (FR)Proposed May 8, 2013
… being considered by the Department are pursuant to this section of ERISA, as well as ERISA section 505. Section 505, in relevant part, provides that the Secretary may prescribe such regulations as the Secretary finds necessary or appropriate to carry out the provisions of title I of ERISA. 29 U.S.C. 1135. Collectively…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsJan 12, 1998related by meaning
ontrol of the use of the IRA
distributions. We are not persuaded by respondent's argument
that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the
forfeiture, and his avoidance of a fine or potentially longer
prison sentence, petitioner should be treated …