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85 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
    IRCFinal Rules (FR)Nov 6, 2020
    …y for the cost of other services ( e.g., in accordance with the PETI rules set forth in 42 CFR part 435, subpart H, and 42 CFR 435.832 for beneficiaries receiving institutional services or other long-term services and supports who are subject to the PETI rules). Under the enrollment interpretation, states would be requ…
  2. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    …ver made the necessary allocation and, therefore, has failed to prove that it complied with section 435 (e) (1) (B) (iii). Respondent’s point is not well taken. There is no requirement in section 435(e) (1) (B) (iii) that any such allocation must be made. This clause is phrased in terms of a test of sales by the taxpay…
  3. 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…
  4. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
  5. 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…
  6. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    n from sec. 457 altogether. We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
  7. 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…
  8. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    2,300. All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue. Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
  9. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …No. 10897-93; and Frank A. Pettisani and Lucille M. Pettisani, docket No. 23719-93. T.C. Memo. 1996-435 UNITED STATES TAX COURT BARRY B. BEALOR AND NANCY L. BEALOR, ET AL., 1 Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 13364-89, 14112-89, Filed September 25, 1996. 17236-89, 26434-89, 27614-…
  10. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …iation/sec. 179 expense 36,179 36,179 --- 36,179 Car and truck expenses 756 756 --- 756 Advertising 435 435 435 --- Repairs and maintenance 71 71 71 --- i. Wages On brief respondent concedes that petitioners have substantiated BJWrelated wages of $65,208, leaving the remaining $3,478 at issue. The record establishes (a…
  11. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008related by meaning
    e Tax Court (and the Tax Court shall have jurisdiction) to determine the appropriate relief available to the individual under this section * * * - 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4 This amendment applies "with respect to liability for taxes arising or remaining unpaid on or after …
  12. T.C. Memo. 1998-388 — Robert B. Keenan v. Commissioner
    IRCCourt RulingsNov 2, 1998
    …). On February 27, 1989, petitioner directed that $250,000 be transferred from his I RA account No. 435 to a new account, Cash Reserve IRA, account No. 26000137860 (account no. 860). On December 4, 1989, petitioner caused a distribution of $90,000 from account No. 860. (By stipulation, petitioner conceded that the 1989…
  13. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …are “not inconsistent with federal labor policy.” M & G Polymers USA, LLC v. Tackett, 574 U.S. 427, 435 (2015). Moreover, employers have “large leeway to design … welfare plans as they see fit.” Black & Decker Disability Plan v. Nord , 538 U.S. 822, 833 (2003). “Vested benefits” are those benefits that survive the expirat…
  14. 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…
  15. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    ies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), petitioner is not liable for the excise tax imposed by section 4980A for 1989. For 1990, petitioner withdrew an amount in excess of $150,000 from his IRA with First National. Accordingly, - 28 - 20 See supra note 15 and accompanying text. Further, …
  16. 91 FR 33900 — Federal Independent Dispute Resolution Operations
    IRCFinal Rules (FR)Jun 4, 2026
    …ge rate) = $118.82. Back to Citation 276.  This was calculated at the time based on an estimated 17,435 of disputes in the Federal IDR process with a notice of certified IDR entity selection. The 2023 proposed rules had an error in this calculation resulting in total annual costs of $2,156,635. The correct calculation …
  17. 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…
  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. 29 C.F.R. § 4022.23(f)(1) — Computation of maximum guaranteeable benefits.
    PBGCRegulationsJan 1, 2017
    …ate of plan termination 2 1 2 3 4 5 6 7 8 9 10 45 0.060 0.117 0.170 0.220 0.268 0.315 0.355 0.395 0.435 0.475 46 .061 .119 .173 .224 .273 .321 .362 .403 .444 .485 47 .062 .121 .176 .228 .278 .327 .369 .411 .453 .495 48 .063 .123 .179 .232 .283 .333 .376 .419 .462 .505 49 .064 .125 .182 .236 .288 .339 .383 .427 .471 .51…
  20. 75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Jul 16, 2010
    …0 will be $8,830,000 (approximately $8,810.000 for service providers and $21,000 for plans), and $1,435,000 (approximately $1,424,000 for service providers and $10,000 for plans in subsequent years. The three-year average cost burden is estimated to be almost $3.9 million. Table 14—Cost Burden   Year 1 Year 2 Year 3 Av…