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83 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …087 entities × 2 hours) × $159.34 = $1,621,125. Back to Citation 634.  The burden is estimated as: [177 financial institutions + (3,960 independent producers × 5%)] × (10 minutes ÷ 60 minutes) = 63 hours. A labor rate of approximately $159.34 is used for a legal professional. The labor rate is applied in the following …
  2. 91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives
    ERISAProposed Rules (FR)Proposed Mar 31, 2026
    …ISA fiduciary will implicate difficult tradeoffs.” Hughes v. Northwestern University, 595 U.S. 170, 177 (2022). And, as discussed above, a fiduciary must act based on “the circumstances as they reasonably appear to [the fiduciary] at the time when he does act and not at some subsequent time when his conduct is called i…
  3. Court of Appeals for the Eleventh Circuit — Ann Johnson v. Russell Investments Trust Company
    ERISACourt RulingsAug 17, 2026
    …“Russell’s strength is their expertise in providing consulting services and investment advice.” Doc 177- 29 at 5. Upon reviewing the memo, the RFP Team selected Russell as one of its four finalists because of its “ [ s ] trong expertise in providing consulting service and investment advice .” Doc. 177-30 at 4. But i n …
  4. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    …erical workers prepare and distribute comparative analyses upon participant request 2,129,516 0.083 177,460 65.99 11,710,585 2.79 2,477,543 Clerical workers maintain recordkeeping 2,129,516 0.083 177,460 65.99 11,710,585 0 0 Total 2,129,536 355,020 23,433,073 2,477,543 1.5. Overall Summary
  5. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    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…
  6. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …ectively, (5) whether TORCH is liable for section 6651(a)(2) failure to pay additions to tax of $11,177.73 and $22,326.43 for the 2003 and 2004 tax years, respectively, and (6) whether petitioners Robert A. and Pearl Fletcher are liable for the section 6662(a) accuracy-related penalty for the 2003, 2004, and 2005 tax y…
  7. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    … the time of conversion, the Cgroup term policy’s conversion credit balance was $84,397.58, and $80,177.70 of that amount ($84,397.58 x 95%) was transferred to the C-group conversion UL policy for potential earning. Dr. Desai will earn these credits in 120 equal monthly installments, beginning October 1996. The convers…
  8. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  9. 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
    … Matters 176 SECTION 5. ON WHAT ISSUES MUST WRITTEN ADVICE BE REQUESTED UNDER DIFFERENT PROCEDURES? 177 .01 Pre-approved plans 177 .02 Employee Plans Compliance Resolution System 177 .03 Chief Counsel 177 .04 Determination letters not issued for requests for minimum funding waivers 177
  10. Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20…
    IRCRevenue ProceduresJan 2, 2019
    …Right to status conference 176 .17 How to request status conference 176 .18 Correct format required 177 SECTION 11.WHAT IS THE PROCESS FOR REQUESTING DETERMINATION LETTERS FOR INDIVIDUALLY DESIGNED PLANS? 177 .01 Requesting determination letters 177 .02 Elimination of remedial amendment cycle for individually designed …
  11. 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…
  12. 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…
  13. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    …FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 177 .01 In general 177 .02 Certain information required in requests for letter rulings or determination letters, as applicable 177 .03 Additional information required in certain circumstances 186 .04 Address to send the …
  14. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    … Date of report 03/11/91 03/11/91 07/10/91 01/20/93 1992 1992 1993 1993 1994 Fund value at yearend $177,095 $177,095 $184,012 $176,364 $148,625 Policy values 177,103 177,103 186,612 178,964 177,545 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 Da…
  15. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
  16. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
  17. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996
    …, An Arizona Professional Corporation, docket No. 19117-90; and Brody Enterprises, Inc., docket No. 177-91. * This opinion supplements our previously filed opinion in Citrus Valley Estates, Inc. v. Commissioner , 99 T.C. 379 (1992), affd. in part and remanded in part 49 F.3d 1410 (9th Cir. 1995). 106 T.C. No. 23 UNITED…
  18. 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…
  19. 88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    ent distribution channel is estimated as: (215 insurance companies−38 large insurance companies) = 177 small insurance companies. Back to Citation 65.  This is estimated as: [(177 small insurance companies × 5 hours) + (38 large insurance companies × 10 hours)] = 1,265 hours. A labor rate of $159.34 is used for a legal…
  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
    …FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS? 177 .01 In general 177 .02 Certain information required in requests for letter rulings or determination letters, as applicable 177 .03 Additional information required in certain circumstances 186 .04 Address to send the …