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 81 T.C. 999 (not yet in the library — opens the official source)
91 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 75 FR 37188 — Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections
    IRCFinal Rules (FR)Jun 28, 2010
    …mit Percentage Number Current Lifetime Limit: Under $1,000,000 0.03-0.06 550-1,050 $1,000,000 to $1,999,999 0.02 4,500-5,000 $2,000,000 plus 0.02 13,600-14,350 Current Annual Limit: Under $250,000 0.19-0.23 550-650 $250,000 to $499,999 0.08-0.10 650-850 $500,000 to $999,000 0.03-0.06 350-700 $1,000,000 to $1,999,999 0.…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005★ strong match
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  3. T.C. Memo. 2011-83 — Bruce A. & Carol Anfinson Brown v. Commissioner
    IRCCourt RulingsApr 12, 2011
    …ium for these 3 years is higher than $1,837. - 6 - In total Mr. Brown paid $44,205 in premiums: $11,999 by check, $28,532 by loans, and $3,674 by dividends. The following table shows how he paid the premium each year: Year Paid by Check Paid by Loan Paid by Dividend
  4. 78 T.C. 395; 78 T.C. No. 27 — Sutherland v. Commissioner
    IRCCourt RulingsMar 9, 1982
    …oner Aviation Equities Trans-America Total number of employees Percent $20,000 1 0 1 0.8 16,000-$19,999 1 2 3 2.4 12,000- 15,999 6 11 17 13.7 8,000- 11,999 4 15 19 15.3 26 28 22.6 $4,000- $7,999 tO 54 56 45.2 0- 3,999 tO 108 124 100.0 Totals 05 I
  5. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …7] The Department also estimates that there are 104,123 self-insured group health plans with 100 to 999 employees and 15,362 self-insured group health plans with 1,000 or more employees.[208]
  6. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006
    … - Respondent determined a deficiency in petitioners’ Federal income tax for 2002 in the amount of $999. Petitioners timely filed a petition with the Court. The sole issue for decision is whether petitioner Patricia Marie Colombell is an active participant in her former employer’s qualified retirement plan and thus ine…
  7. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    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…
  8. 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…
  9. T.C. Memo. 2001-118 — Roydell Campbell v. Commissioner
    IRCCourt RulingsMay 17, 2001
    … $3,960. By the terms of the February 6, 1997, loan, petitioner agreed to pay $110.73 biweekly over 999 pay periods. The 29th loan was made on April 17, 1997, in the amount of $690. Once again, all existing loans were rolled into the new loan. By the terms of the April 17, 1997, loan, petitioner agreed to pay $112.33 b…
  10. 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…
  11. IRCCourt RulingsAug 3, 1979related by meaning
    to a reasonable concern of Congress. Thus section 219(b)(2) does not create an unconstitutional presumption. II. Liability for Section U973 Excise Tax Petitioners argue that, if we uphold the constitutionality of section 219(b)(2), then the 6-percent excise tax imposed by section 4973 cannot be imposed because there ar…
  12. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    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…
  13. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    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…
  14. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    al rules proceeding through the Federal IDR process, the annual burden would be 51,999 hours, with an associated equivalent cost of $5.2 million.[236] The open negotiation notice must be sent within 30 business days beginning on the day the provider or facility receives an initial payment or a notice of denial of payme…
  15. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    tz v. Commissioner , supra , and Kasey v. Commissioner , supra , is also misplaced. In those cases, we held that the taxpayers constructively received income to which they were entitled but which was garnished and remitted to judgment creditors. In neither case is there any indication that the taxpayers disputed their …
  16. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
    IRCCourt RulingsSep 13, 1990related by meaning
    as to utilize the estate tax unified credit to its fullest extent. Kenneth G. Coveney, for the petitioner. William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
  17. Treas. Reg. § 1.423-2(d)(3) — Employee stock purchase plan defined.
    IRCRegulationsJan 19, 2017
    …y related corporation of M, M may grant an option to U under its employee stock purchase plan for 4,999 shares, because immediately after the grant of the option, U would not own 5 percent or more of the combined voting power or value of all classes of M stock actually issued and outstanding at such time. The 4,999 sha…
  18. 85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights
    ERISAProposed Rules (FR)Proposed Sep 4, 2020
    …0,390 N/A <1% <1% Small Firms 1,220,890 50,390 100 4 2 <100,000 46,505 50,390 22 108 55 100,000-499,999 251,618 50,390 41 20 10 500,000-999,999 696,025 50,390 14 7 4 1M-2,49M 1,531,804 50,390 12 3 2 2.5M-4.99M 3,390,789 50,390 5 1 1 5M-7.49M 5,779,106 50,390 2 <1 <1 7.5M-9.99M 7,854,990 50,390 1 <1 <1 10M-14.99M 10,752…
  19. 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…
  20. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    tever source derived, including (but not limited to) the following items: ******* (11) Pensions; SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…