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85 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  2. 89 FR 43636 — Abandoned Plan Regulations
    ERISAFinal Rules (FR)May 17, 2024
    …s) × (75.3% proportion of small plans) × (10% abandonment rate of plans with firms in CHPT 7)] + (1,340 plans currently using the program); 11,500 participants ≉ 11,522 = 1,806 plans × 6.38 participants. Back to Citation 57.  6,000 ≉ 6,002 = [(12,900 CHPT 7) × (48% small plans offering DC plans) × (75.3% proportion of …
  3. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    s, the total annual maintenance and reporting burden is estimated to be 965,340 hours with an equivalent total cost of approximately $137,451,960.[50] The Departments and OPM consider this to be an upper-bound estimate and expect maintenance costs to decline in succeeding years as issuers gain efficiencies and experien…
  4. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …bition on royalt y payments affected only royalty payments to a commonly owned company. Id. at 339- 340. It held that First Security Bank had established the general principle that a section 482 allocation cannot be made unless “control was utilized to shift income”. Pro cter & Gamble Co. v. Commissioner , 95 T.C. at 3…
  5. 89 T.C. 287; 89 T.C. No. 25 — Larotonda v. Commissioner
    IRCCourt RulingsAug 13, 1987
    …uch, petitioner is deemed, pursuant to section 72(m)(4)(A), to have constructively received the $22,340.94 in levied funds as a distribution from the Keogh account. Sec. 1.72-17(d)(l), Income Tax Regs. This amount is includable in petitioners’ 1981 gross income to the extent deductions were obtained for the contributio…
  6. T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated …
    IRCTreasury DecisionsDec 6, 2021
    …nts Number of Responses Burden Hours Per Respondent Total Burden Hours Total Cost 519 519 1,860 965,340 $137,451,960 The Departments and OPM estimate the three-year average annual total burden for all 519 issuers and FEHB carriers to develop, build, and maintain needed IT systems changes to collect and aggregate the re…
  7. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    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. …
  8. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  9. Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in …
    IRCRevenue RulingsDec 28, 2009related by meaning
    ment 2009-88 Announcement 2009-88 A list is provided of organizations now classified as private foundations. Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
  10. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997★ strong match
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
  11. IRCRegulationsSep 17, 2024
    …ensation and make the following elections: Employee Compensation Electivecontribution A $100,000 $4,340 B 60,000 2,860 C 45,000 1,250 (ii) For each employee, the ratio of elective contributions to the employee's compensation for the plan year is: Employee Ratio of elective contribution to compensation ADR(percent) A $4…
  12. 88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …equent years Burden hours Equivalent burden cost Burden hours Equivalent burden cost Legal 8,430 $1,340,036 8,430 $1,340,036 Total 8,430 1,340,036 8,430 1,340,036 For the purposes of this analysis, the Department assumes that, on average, an Independent Producer would receive 10 requests per year and that preparing and…
  13. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …the evidence. See Knudsen v. Commissioner , 131 T.C. 185, 189 (2008), supplementing T.C. Memo. 2007-340. In this case we discerned no evidentiary tie on any material issue of fact. See, e.g. , id. II. Technical Requirements for a Charitable Contribution Deduction Section 170(a) (1) allows a deduction for a charitable c…
  14. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    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…
  15. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    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 …
  16. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    IRCCourt RulingsNov 21, 2007
    …6 Other income -07 Gross income . Add lines 5 and 6 114,63 4 Expenses : 10 Car and truck expenses 2,340 $2,340 .00 $1,270 11 Commissions and fees 7,900 8,560 .00 5,330 13 Depreciation and section 179 3,756 3,756 .00 1,430
  17. 74 T.C. 1106; 2 Employee Benefits Cas. (BNA) 2385 — Federal Land Bank Asso. v. Commissioner
    IRCCourt RulingsAug 26, 1980
    …dy B. Freeman6,120 14. Betty J. Roberts5,700Elected 15. Hazel S. Willis5,520 16. Cathy T. Crawford5,340 17. Donna R. Pipes5,340 18. Marie Pangle5,340 19. Celia Anne Jackson5,100 20. Juanita Phillips4,920 21. Betty B. Nicholson4,440 22. Donna M. Ingle4,140 23. Sandra Mann4,020 *82 For the plan year beginning September 1…
  18. 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…
  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. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…