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95 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ld a second trial at which petitioner would introduce new evidence in support of that position. With respect to petitioner's tax duplication argument, petitioner asserts: As a result of the Court's Opinion in this case and without a Rule 155 proceeding, respondent will be in a windfall position-it will have collected t…
  2. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013
    …P account as outlined in the MSA. In 2007, and pursuant to the amended MSA, petitioner withdrew $25,248 from the TSP account, which constituted his entire 50% interest. Also pursuant to the amended MSA, once petitioner received the distribution check, he transferred $24,248 to Ms. Toombs Petitioner paid a commercial ta…
  3. IRCRegulationsSep 17, 2024★ strong match
    …tribution requirements added by the Tax Equity and Fiscal Responsibility Act of 1982, Public Law 97-248, 96 Stat. 324 (1982) (TEFRA), were retroactively repealed in 1984, the transitional election rule in section 242(b) of TEFRA (referred to as a section 242(b)(2) election in this paragraph (h)) was preserved. While se…
  4. 77 FR 74063 — Amendments to the Abandoned Plan Regulations
    ERISAProposed Rules (FR)Proposed Dec 12, 2012
    …uired to prepare required plan information, and to review and sign the forms. This results in about 248 hours (495 plans × .5 hours) of clerical staff time with an associated cost burden of $7,000 (495 plans × .5 hours × $28.21 per hour), and 248 hours (495 plans × .5 hours) of a financial professional's time with an a…
  5. 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. …
  6. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    of Claims, or the district court of the United States for the District of Columbia may make a declaration with respect to such initial qualification.” It is clear that Congress intended that the procedures under secs. 7476 and 7428 be similar. See S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 624-627); H. Rept. 94-658 (…
  7. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    …47 .03 Opinion and advisory letters 247 .04 VCP compliance statements – electronic submissions only 248 SECTION 32. WHAT IS THE EFFECT OF THIS REVENUE PROCEDURE ON OTHER DOCUMENTS? 248 SECTION 33. EFFECTIVE DATE 248 SECTION 34. PAPERWORK REDUCTION ACT 248 DRAFTING INFORMATION 249 APPENDIX A SCHEDULE OF USER FEES 250
  8. 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…
  9. 91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure
    ERISAProposed Rules (FR)Proposed Jan 30, 2026
    …duced out-of-pocket costs for participants (the sum of the copayment and coinsurance) by 1 percent.[248]
  10. U.S. Tax Court — Charles & Kathy A. Welker v. Commissioner
    IRCCourt RulingsDec 15, 2009
    …tributions from the IRA in .the following amounts : $69,330 ; $44,200 ; $81,096 ; $80,039 ; and $66,248, respectively . Each of these amounts was reported on a Form 1099-R designating a distribution code 3 indicating an early distribution due to,disability . The fair market value of the IRA account at the end of 2005 w…
  11. T.C. Memo. 2000-100 — Ronna Joan Robertson v. Commissioner
    IRCCourt RulingsMar 24, 2000
    …rldly Connections, Inc. The documentation submitted indicates that in January 1994 petitioner paid $248.95 for Delaware State filing fees, registered agent fees, a corporate kit, and basic mail forwarding service. Petitioner also remitted an additional $155 in November 1994 for advanced payment of agent fees and renewa…
  12. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  13. 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…
  14. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989related by meaning
    ended returns, The conditions were not met, and it was not an abuse of discretion to disqualify the plan. Revocation of Favorable Determination Letter The Supreme Court has held that the Commissioner has broad discretion under section 7805(b) in deciding whether to revoke a ruling retroactively, and that his determinat…
  15. 79 FR 27731 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)May 15, 2014
    …rity: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, Rate Set 248, as set forth below, is added to the table. 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 annuities (pe…
  16. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
  17. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997★ strong match
    …545 Surrender value 157,104 157,104 166,613 161,097 162,772 Addit. contr. available 202,263 197,155 248,761 243,663 296,318 Date of report 09/94 03/95 09/94 03/95;10/95 10/95 On March 31, 1989, Prime forwarded to On-Site its 1988 summary plan description. On April 4, 1990, Prime forwarded to On-Site its 1989 summary pl…
  18. 87 FR 60357 — User Fees Relating to Enrolled Actuaries
    IRCProposed Rules (FR)Proposed Oct 5, 2022
    …costs to calculate indirect costs of $990,531, for a total cost for the three-year period of $2,674,248. The calculation of the total cost of the enrolled actuary enrollment and renewal of enrollment program for 2022 through 2024 is shown below: ( printed page 60361) Direct Costs $1,683,717 Overhead at 58.83% + 990,531…
  19. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
  20. Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 2, 2024
    …7 Opinion letters on § 403(b) prototype plans pursuant to Rev. Proc. 2013-22 and Rev. Proc. 2014-28 248 .08 Opinion letters on pre-approved plans submitted pursuant to Rev. Proc. 2023-x37 (§ 401(a)) 248 .09 Advisory letters on § 403(b) VS plans pursuant to Rev. Proc. 2013-22 and Rev. Proc. 2014-28 248 .10 Determination…