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89 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2006-11 — Richard Bradley v. Commissioner
    IRCCourt RulingsJan 26, 2006
    …ection 7491(a)(2). Therefore, the burden of proof remains with petitioner. II. Distributions of $15,322.69 and $7,000 A. General Section 408(d)(1) provides that any amount paid or distributed from a qualified retirement plan generally must be included in gross income by the distributee in the manner provided under sect…
  2. Treas. Reg. § 1.72(p)-1(b) — Loans treated as distributions.
    IRCRegulationsSep 17, 2024
    …the new loan is $40,000, the outstanding balance on January 1, 2006, of the loan it replaces is $33,322, and the highest outstanding balance of loans from the plan during 2005 was $40,000. Accordingly, under section 72(p)(2)(A), the sum of the new loan and the outstanding balance on January 1, 2006, of the loan it repl…
  3. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …e end of that year, the conversion credit balance was $7,485.21 ($4,865.74 + $2,962.50 - $665.36 + $322.33); the $322.33 is the interest of 4.5 percent earned on the conversion credit balance (($7,485.21 - $322.33) x 4.5% = $322.33)). Of the conversion credit balance, $6,755.40 could have been transferred at this time …
  4. 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…
  5. 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…
  6. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …ations 693,105 = 770,117 Plans × 90% Using a Service Provider 5/60 70.29 57,759 4,059,862 Total 138,322 $18,646,718 Table 8—Cost for Distribution of New Paper Benefit Statements for 2020 Safe Harbor [Year 1] Description Affected entities Pages per disclosure Material costs per page Distribution costs per disclosure Tot…
  7. 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…
  8. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    fic terms and requirements that, in a reasonable manner, interpret and carry out the general concepts embodied in the statute and legislative history. Thus, we hold that the temporary regulation is valid. Applicability of Temporary Regulation to Petitioner's Yearend Bonus Payments In the alternative, petitioner argues …
  9. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    … hours Equivalent burden cost Burden hours Equivalent burden cost Insurance Sales Agent 250,000 $41,322,500 250,000 $41,322,500 Total 250,000 41,322,500 250,000 41,322,500 1.3.1.5 Mailing Cost for Disclosures Sent From Independent Producers to Retirement Investors As discussed at the beginning of the cost section, the …
  10. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  11. 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…
  12. 85 FR 42706 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits
    PBGCFinal Rules (FR)Jul 15, 2020
    …S 1. The authority citation for part 4022 continues to read as follows: Authority: 29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344. 2. In appendix B to part 4022, rate set 322 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…
  13. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  14. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
    IRCCourt RulingsJan 30, 2007
    …ll Lynch, to protect Taxable income Cash Pay 123,000 Merrill Lynch, to protect Taxable income Other 322,962 Merrill Lynch, to protect Taxable income Total 1,118,870 Petitioners reported taxable income of $213,977, tax of $60,080, tax on IRAs and other retirement plans of $63,717, and total tax 4(...continued) 2000. - 1…
  15. 87 FR 73822 — Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights
    ERISAFinal Rules (FR)Dec 1, 2022
    …f affected entities in section IV.C. Back to Citation 278.  The burden is estimated as follows: 149,322 plans × 4 hours = 597,288 hours. A labor rate of $153.21 is used for a legal professional. The cost is estimated as follows: 149,322 plans × 4 hours × $153.21 = $91,510,494. Back to Citation 279.  The per-plan burden…
  16. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    ity under an annuity, endowment, or life insurance contract to the extent such an amount is attributable to the taxpayer's investment in the contract. Section 1.72-15(b), Income Tax Regs., provides that, as a general rule, section 72 does not apply to any amount received as an accident or health benefit. Section 104(a)…
  17. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
  18. Court of Appeals for the Fourth Circuit — Richard Kelly v. Altria Client Services, LLC
    ERISACourt RulingsAug 10, 2026
    … for appropriate remedies, sanctions, and ready access to the Federal courts.’ ” Marks v. Watters , 322 F.3d 316, 322 (4th Cir. 2003) (quoting 29 U.S.C. § 1001(b) ). USCA4 Appeal: 25-1350 Doc: 89 Filed: 08/10/2026 Pg: 3 of 21 4 As to Kelly’s third claim, h e allege d that, despite his request, the p lan administrator r…
  19. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
  20. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …iding for it by statute. See, e.g., secs. 1(f), 151(d)(4); Bartley v. Commissioner, T.C. Memo. 1998-322 n.10. - 7 -