Search the Pension Law Library

1. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
   ERISAProposed Rules (FR)Proposed Feb 25, 2026
   …e Providers) 3,552 Service Providers 1 $181.06 3,552 643,125 Notice Preparation (In-House) 29,971 = 299,712 Plans × 10% Not Using a Service Provider 1 181.06 29,971 5,426,592 Adding Contact and Plan Information to Drafted Notices 269,741 = 299,712 Plans × 90% Using a Service Provider 5/60 70.29 22,478 1,580,009 Total 5…
2. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
   IRCCourt RulingsSep 14, 1993★ strong match
   …determined that you are not entitled to earned income credit shown on your return in the amount of $299.00 because you do not meet the requirements of section 32 of the Internal Revenue Code. With respect to the $299 earned income credit in adjustment (c), the parties have stipulated as follows: If it is determined tha…
3. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
   IRCCourt RulingsApr 11, 2012
   …s $379,000 $411,400 $500,000 108 213 125,266 138,663 Salaries and wages Pension, profit-sharing, 27 299 22,731 21,789 etc., plans - 8 - Employee benefit programs -- --t - Consultant fees 99,000 90,453 101,000 For the years at issue Diogenes reported the following relevant amounts on its Federal corporate income tax ret…
4. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
   ERISAProposed Rules (FR)Proposed Jan 30, 2026
   …e findings are consistent with other research indicating increased health risks from non-adherence.[299] Additionally, health-related quality of life data from MEPS indicates that adherence is also associated with significantly higher health-related quality of life scores for both mental and physical health.[300] To as…
5. 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…
6. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
   IRCRegulationsSep 9, 2016
   …10, solely for purposes of determining the adjustment for investment experience during 2010, is $40,299 ($50,000—$9,701), and the adjustment for investment experience is $4,030 ($40,299 × 10%).
7. PLR 200931049 — Ten or More Employer Plan Exception
   IRCPrivate Letter RulingsJul 31, 2009
   …alue Life Insuran ce In Neonatology Associates et al., v. Commissioner , 115 T.C. 43 (2000), aff’d. 299 F.3d 221 (3d Cir. 2002), a trust claimed to be a § 419(e) welfare benefit fund that provided current life insurance benefits (that is, a promise to pay an employee’s bene ficiary a death benefit should the employee d…
8. 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…
9. 83 FR 40453 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
   PBGCFinal Rules (FR)Aug 15, 2018
   …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 299 is added at the end of the table to read as follows: Appendix B to Part 4022—Lump Sum Interest Rates For PBGC Payments * * * * * Rate set For plans with a valuation date Immediate annuity rate (percent) Deferred annu…
10. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
11. 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…
12. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
13. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
14. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    tract unless such amounts are specifically excluded from gross income under other provisions of chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific statutory exclusion. See Commissioner v. Glenshaw Glass Co. , 348 U.S. at 429-431. Under section 72(t), a …
15. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    IRCCourt RulingsSep 3, 1998
    …ul Clendenen 1,949.82 0 1989 total 13,199.82 0 1990 Howard E. Clendenen 9,000.00 0 Paul Clendenen 3,299.88 0 1990 total 12,299.88 0 1991 Howard E. Clendenen 8,250.00 0 Paul Clendenen 3,975.00 0 1991 total 12,225.00 0 These contributions were reflected in the trust's Forms 5500-C Return/Report of Employee Benefit Plan f…
16. T.C. Memo. 2015-244 — Jeremiah J. O'Connor & Mary K. O'Connor v. Commissioner
    IRCCourt RulingsDec 16, 2015
    , P.A. v. Commissioner, 115 T.C. 43, 99 (2000), a , 299 F.3d 221 (3d Cir. 2002); sec. 1.6664-4(b)(1), Income Tax Regs.; cf United States v. Boyle, 469 - 31 - [*31] U.S. 241, 251 (1985). A taxpayer may rely on the advice of any tax adviser, lawyer, or accountant. See Boyle, 469 U.S. at 251. Reliance on a professional ta…
17. U.S. Tax Court — Andrea C. Casula v. Commissioner
    IRCCourt RulingsMay 5, 2008
    …questing spouse in subsequent years . Rev . Proc . 2003-61, sec . 4 .03(2)(a)(vi), 2003-2 C .B . at 299 . With respect to this inquiry, there is no evidence outside of the year at issue . Accordingly, we find this factor neutral . As to the seventh factor, abuse, petitioner has offered no evidence that she suffered any…
18. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984related by meaning
    rectly involved in such ruling. * * *” See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …
19. 85 FR 40834 — Improving Investment Advice for Workers & Retirees
    ERISAProposed Rules (FR)Proposed Jul 7, 2020
    …xemption. SEC-Registered Investment Advisers (IAs) As of December 2018, there were approximately 13,299 SEC-registered IAs [82] and 17,268 state-registered IAs.[83] An IA must register with the appropriate regulatory authorities, with the SEC or with state securities authorities. IAs registered with the SEC are general…
20. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020related by meaning
    sis test. FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose. Sandra M. Conard, pro se. Scott W. Forbord and Mark J. Miller, for respondent. OPINION TORO, Judge: A taxpaye…