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92 documents · 0.53sAllIRCERISAPBGCJoint Board
  1. 111 T.C. No. 12 — Robert C. & Nancy L. Arnold v. Commissioner
    IRCCourt RulingsSep 28, 1998
    …000 January 1990 44,000 January 1991 44,000 January 1992 44,000 January 1993 44,000 November 1993 6,776 Petitioner received the $6,776 distribution in November 1993 to
  2. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute. II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
  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. 50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner
    IRCCourt RulingsMay 29, 1968
    … a trust, or otherwise segregate from the general funds of its business any part of the claimed $36,776.95 severance-pay liability. In his statutory notice of deficiency for the taxable year ending on March 31,1960, respondent disallowed petitioner’s claimed severance-pay deduction of $36,776.95. He did so on the theor…
  5. Treas. Reg. § 1.417(e)-1(d)(3)(ii)(B) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    less than $187,776 (that is, $1,500 × 12 × 10.432). (4) Analysis of minimum amount of the total single-sum distribution. To satisfy the requirements of section 417(e)(3) and this paragraph (d), the total single-sum distribution received by Q may not be less than the sum of the minimum single-sum distribution with respe…
  6. 88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAProposed Rules (FR)Proposed Nov 3, 2023
    …35 broker-dealers × 10%) + (15,775 registered investment advisers × 10%) + (151 insurers × 10%) = 1,776 financial institutions updating existing disclosures. The number of financial entities needing to draft their written acknowledgement is estimated as: (10 robo-advisers + 930 pension consultants + 20 investment compa…
  7. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020★ strong match
    … his customers. II. Mrs. Benton's Income Mrs. Benton received and reported wages of $30,911 and $14,776 from a law firm and a staffing agency, respectively, during the year in issue. Mrs. Benton was laid off during part of the year in issue and received unemployment compensation of $9,186. Mrs. Benton also received and…
  8. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997related by meaning
    7,676 represents the imposition of additional tax under section 72(t) on petitioner's premature retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of proof on this issue. Rule 142(a). However, the parties stipulated that $20,655.42 of that distribution …
  9. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005related by meaning
    Commissioner , 83 T.C. 755, 791 n.28 (1984); Kahler v. Commissioner , 18 T.C. 31, 34-35 (1952); Roberts v. Commissioner , T.C. Memo. 2002-281. In the instant case, the record reflects that the original check was not subject to substantial limitations, and petitioner makes no contention otherwise. Consequently, we find…
  10. 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…
  11. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002
    …ncome 40,832.56 Line 23. IRA deduction 4,000.00 Line 28. Self-employed health insurance deduction 4,776.70 Line 32. Add lines 23 through 31a 8,776.70 Line 33. Subtract line 32 from line 22 * * * adjusted gross income 32,055.86 Line 36. * * * itemized deductions * * * 30,458.37 Line 37. Subtract line 36 from line * * * …
  12. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  13. Treas. Reg. § 1.436-1(d)(3)(v) — Limits on benefits and benefit accruals under single employer defined benefit plans.
    IRCRegulationsSep 9, 2016
    …e participant's lifetime. The PBGC maximum benefit guarantee amount at age 55 is assumed to be $362,776 for 2010. (ii) Participant R retires at age 55 in 2010 and is eligible to receive a level lifetime annuity of $1,200 per month beginning immediately. Instead, Participant R elects to receive a benefit under the socia…
  14. 91 FR 46602 — Electronic Disclosure by Group Health Plans Under ERISA
    ERISAProposed Rules (FR)Proposed Jul 23, 2026
    …-profit institutions. Respondents: 7,156,384. Responses: 223,433,165. Estimated Total Burden Hours: 776,430. Estimated Total Costs: $18,634,326. Description:
  15. 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…
  16. T.C. Memo. 2010-262 — Hal Hollingsworth v. Commissioner
    IRCCourt RulingsDec 2, 2010
    …tice of deficiency showing a deficiency in income tax of $8,883 and a section 6662(a) penalty of $1,776.60. Respondent's adjustments to petitioner's 2005 income tax return which remain unresolved include: (1) Disallowing petitioner's $21,070 of Schedule C expenses; (2) disallowing petitioner's $16,951 Schedule A deduct…
  17. 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…
  18. 50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner
    IRCCourt RulingsAug 26, 1968related by meaning
    ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
  19. T.C. Memo. 1998-295 — Shedco, Inc. v. Commissioner
    IRCCourt RulingsAug 12, 1998★ strong match
    …the congressional mandate in some reasonable manner.'" Estate of Lang v. Commissioner , 613 F.2d at 776 (quoting Gino v. Commissioner , 538 F.2d 833, 835 (9th Cir. 1976)); see also Propstra v. United States , supra . Petitioner contends that, when made, the loan was a prudent investment. In support of its contention, p…
  20. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …the Relationship and Conflict of Interest disclosure + $41,322,500 for the rollover disclosure) + ($776,863 to prepare and send disclosures + $145,230 for material and postage costs) + ($1,455,103 for additional compensation disclosure preparation + $10,998 for materials and postage) = $88,115,522.The cost in subsequen…