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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   … (1972) (a case involving tax years 1955 to 1959) In Commissioner v. First Sec . Bank , 405 U.S. at 396, a holding company 122 owned two banks 123 and an insurance company. 124 Customers of the two banks sometimes wanted to buy credit-life insurance; the banks would refer these customers to an unrelated insurance compa…
2. 81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments
   ERISAFinal Rules (FR)Jul 1, 2016
   or knowing Recordkeeping $20-198 $198-396 $396-989 Monetary violations 20-198 198-396 Employment of homeworkers without a certificate 198-396 396-989 Other violations of statutes, regulations or employer assurances 20-198 198-396 396-989 PART 570—CHILD LABOR REGULATIONS, ORDERS AND STATEMENTS OF INTERPRETATION 23. The…
3. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
   IRCCourt RulingsSep 18, 1996related by meaning
   sents taxable earnings from petitioner's IRA and that such amount is properly includable in petitioners' gross income for 1990. Sec. 408(d)(1). - 25 - In view of our conclusion, supra , that petitioner's Transfer Refund qualifies for tax-free rollover treatment in 1989 under section 402(a)(5)(D), we understand petition…
4. PLR 200648028 — Definitions and Special Rules
   IRCPrivate Letter RulingsDec 1, 2006
   … the payment should be applied, the Service must follow such designation. Hirsch v. United States , 396 F. Supp. 170, 172 (S.D.Ohio1975), 75-1 USTC ¶9348, 35 A.F.T.R.2d 75-1358. See also , Muntwyler v. United States , 703 F.2d 1030, 1032 (7 th Cir.1983) (citing O’Dell v. United States , 326 F.2d 451, 456 (10 th Cir.196…
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. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
   IRCCourt RulingsJul 5, 1983related by meaning
   the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
7. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
   IRCCourt RulingsJul 30, 1985related by meaning
   the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
8. Treas. Reg. § 1.430(d)-1(f)(9) — Determination of target normal cost and funding target.
   IRCRegulationsSep 9, 2016
   …iated with Participant E's assumed age 50 withdrawal benefit in the 2009 actuarial valuation is $68,396.75. This is equal to the sum of: $6,925.29, which is the present value of payments expected to be made during the year the participant turns age 65 (the 20th year after the valuation date), using the second segment i…
9. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
   IRCCourt RulingsDec 19, 1995★ strong match
   …r section 72(t). 3 - 3 - Commissioner , 89 T.C. 46, 48 (1987); Atlee v. Commissioner , 67 T.C. 395, 396 n.2 (1976); Hedrick v. Commissioner , 63 T.C. 395, 396-397 (1974); Alexander v. Commissioner , 61 T.C. 278, 288 n.6 (1973); Stengel v. Commissioner , T.C. Memo. 1992-570, affd. without published opinion 996 F.2d 1227…
10. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005★ strong match
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
11. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
12. 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…
13. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    ies thereby created. We likewise hold that sec. 220(b)(3)(A)(iv) is not applicable to disallow petitioners’ claimed IRA deductions. See note 16 supra. Since there is a complete absence in the legislative history of sec. 219 as to whether art. Ill judges were to be allowed the benefits of IRA contributions, we cannot sp…
14. 77 FR 74063 — Amendments to the Abandoned Plan Regulations
    ERISAProposed Rules (FR)Proposed Dec 12, 2012
    … sent by mail and that the rest will be submitted electronically (495 plans × .8 fraction by mail = 396 plans send notice by mail). Therefore, mailing costs include $6.35 for postage and email receipt of delivery. The mailing costs include paper and print cost of five cents per page. The model notice is three pages. Th…
15. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017
    …problems with the discretionary award regime. See Whistleblower 11332-13W v. Commissioner, 142 T.C. 396, 400 (2014). TRHCA sec. 406 amended section 7623 to require the Secretary to pay whistleblower awards under certain circumstances. TRHCA sec. 406(a)(1)(D), 120 Stat. at 2959 (adding to section 7623(b)). Under section…
16. 91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors
    ERISAProposed Rules (FR)Proposed Feb 25, 2026
    …877 $64,829,163 $0 $32,414,582 Total Costs in Year 1 $133,931,975 $154,823,812 $79,988,274 $136,783,396 Total Costs in Year 2 $40,736,877 $64,829,163 $0 $32,414,582 ( printed page 9228) Transfers Total Transfers (Annual) $451,779 $719,220 $0 $359,610 1  Years 1 and 2 are presented to show the effects of different assum…
17. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974
    …s made a journal entry on B-G’s books, debiting the “Retirement Income Plan” expense account by $27,396.55 and crediting the “Accrual” expense account by the same amount. Earlier in the year B-G had purchased in the name of the plan securities with a value of $7,101.83. On or about May 17,1967, B-G purchased for the pl…
18. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
19. 85 FR 78742 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age
    PBGCFinal Rules (FR)Dec 7, 2020
    …100 3,100 2026 751 751 3,172 3,172 2027 768 768 3,245 3,245 2028 786 786 3,319 3,319 2029 804 804 3,396 3,396 2030 822 822 3,474 3,474 2031 or later 841 841 3,554 3,554 1  Applicable tables for valuation dates before 2021 are available on PBGC's website ( www.pbgc.gov). 2  Table II-A. 3  Table II-B. 4  Table II-C. * * …
20. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    es that the prior services of the employee were performed for the same employer. The same employer was involved in Lucas v. Ox Fibre Brush Co., supra. Generally, the separateness of different taxable entities must be respected. Burnet v. Clark, 287 U.S. 410 (1932); Dalton v. Bowers, 287 U.S. 404 (1932). This case is no…