IRCCourt RulingsOct 8, 2003related by meaning
ng this amount. Subsequently,
J.D. merged into Clarkston pursuant to section 368, and filed a
final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the
final return year of J.D. eliminated by book entry as a result of
the merger.
- 5 -
Discussion
Respondent’s …
ERISACourt RulingsApr 28, 1995
…perform whatever tests of the Plan's books
and records he deems necessary. According to 29 U.S.C.
§ 1027, the Plan:
Shall maintain records on the matters of which
disclosure is required which will provide in
sufficient detail the necessary basic information
and data from which the documents thus required may
be verifie…
IRCCourt RulingsFeb 18, 1997related by meaning
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 …
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 RulingsApr 26, 2005
…he scope
of this relief from the anti-cutback rule of section 411(d)(6).
See T.D. 8768, 1998-1 C.B. 1027, 1029-1030. Section
1.417(e)-1(d)(10)(i), Income Tax Regs., provides the general rule
that a plan amendment that changes the interest rate, the time
for determining the interest rate, or the mortality assumptions
IRCRegulationsMay 18, 2016
…ounts described in section 4045(b) of the Employee Retirement Income Security Act of 1974, 88 Stat. 1027 (relating to the recapture of certain payments),
(c)(2)(ii) (ii) Any arrangement for the withholding of Federal, State or local tax from plan benefit payments,
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA ERISAProposed Rules (FR)Proposed Jul 23, 2026
…The authority citation for part 2520 is revised to read as follows:
Authority:
29 U.S.C. 1021-1025, 1027, 1029-1031, 1059, and 1134-1135; and Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). Sec. 2520.101-2 also issued under 29 U.S.C. 1132, 1181-1183, 1181 note, 1185, 1185a-b, 1191, and 1191a-c. Sec. 2520.…
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…
IRCProposed Rules (FR)Proposed May 13, 2026
…TH PLANS
3. The authority citation for part 2590 continues to read as follows:
Authority: 29 U.S.C. 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a-n, 1191, 1191a, 1191b, and 1191c; sec. 101(g), Pub. L. 104-191, 110 Stat. 1936; sec. 401(b), Pub. L. 105-200, 112 Stat. 645 (42 U.S.C. 651 note); sec. …
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
… The authority citation for part 2520 continues to read as follows:
Authority:
29 U.S.C. 1021-1025, 1027, 1029-31, 1059, 1134 and 1135; and Secretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012). Sec. 2520.101-2 also issued under 29 U.S.C. 1132, 1181-1183, 1181 note, 1185, 1185a-b, 1191, and 1191a-c. Sec. 2520.10…
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…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…TH PLANS
5. The authority citation for part 2590 continues to read as follows:
Authority:
29 U.S.C. 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a-n, 1191, 1191a, 1191b, and 1191c; sec. 101(g), Pub. L. 104-191, 110 Stat. 1936; sec. 401(b), Pub. L. 105-200, 112 Stat. 645 (42 U.S.C. 651 note); sec. …
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…
IRCCourt RulingsAug 8, 2005
…hat designates which of
those interests and rights is taxed. See Walter v. United
States
, 148 F.3d 1027, 1029 (8th Cir. 1998) (“We agree that the
law of negotiable instruments provides a useful backdrop, but it
cannot trump the doctrine of constructive receipt as developed in
the Internal Revenue Code and its implemen…
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…
IRCCourt RulingsNov 23, 2016
… Fargo reported
3See Fed. R. Evid. 201; see also Estate of Reis v. Commissioner, 87 T.C.
1016, 1026-1027 (1986).
4Blair v. Commissioner, T.C. Memo. 2002-189, 84 T.C.M. (CCH) 137, 141
(2002).
5Blair v. Commissioner, T.C. Dkt. No. 6368-05L (Feb. 2, 2006) (order and
decision).
6Blair v. Commissioner, T.C. Dkt. No. 6368-05…
IRCCourt RulingsMay 12, 1971related by meaning
g $1,000,
may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
ERISACode / StatuteJan 6, 2017
…e I of the Employee Retirement Income Security Act of 1974".
(a)(2)(B) (B)
(a)(2)(B)(i) (i) Section 1027 of such title 18 is amended by striking out "Welfare and Pension Plans Disclosure Act" and inserting in lieu thereof "title I of the Employee Retirement Income Security Act of 1974", and by striking out "Act" each p…
IRCCourt RulingsMar 7, 2000
…cable or
without merit. Rowlee v..Commissioner, 80 T.C. 1111 (1983);
McCoy v. Commissioner, 76 T.C. 1027 (1981), affd. 696 F.2d 1234
(9th Cir. 1983). We see no need to repeat these discussions
here.
Suffice it to say that petitioner is not exempt from having
to pay Federal income taxes.· Abrams v. Commissioner, 82 T.C.…