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91 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 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 $4,865.74 ($2,373.60 + $2,890.50 - $607.89 + $209.53); the $209.53 is the interest of 4.5 percent earned on the conversion credit balance (($4,865.74 - $209.53) x 4.5% = $209.53)). Of the conversion credit balance, $2,311.23 could have been transferred at this time …
  2. 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…
  3. ERISARegulationsJan 1, 2017★ strong match
    [Reserved]
  4. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    e not binding on any government agency other than the United States Department of Labor." On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise tax deficiencies pursuant to section 4975(a) and (b), as well as additions to tax. Respondent determine…
  5. T.C. Memo. 2020-152 — Brett John Ball v. Commissioner
    IRCCourt RulingsNov 10, 2020
    …OMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22833-14. Filed November 10, 2020. P caused $209,600 to be distributed from his SEP-IRA to an LLC that he controlled. The LLC lent the received amount in the name of the SEP-IRA and, eventually, contributed the amounts repaid on the loans (plus interest) to the SEP…
  6. 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
    …QUALIFIED PLANS ONLY)? 208 .01 Scope 208 .02 Employer must request the determination under § 414(n) 209 .03 Forms 209 .04 Employer is responsible for determining continuing status under § 414(n) 209 .05 Pre-approved plans 209 .06 Required information for § 414(n) determination 209
  7. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  8. 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
    …ge in facts applied retroactively 208 .06 Not otherwise generally revoked or modified retroactively 209 .07 Will not apply to a similar transaction in same year or any other year 209 .08 Retroactive effect of revocation or modification applied to a continuing action or series of actions 209 .09 May be retroactively rev…
  9. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    …umulative Paid Cumulative Difference -0-4,184,771 1,856,154 3,504,159 680,612 CD OO <Ji 1,025,021 5,209,792 1,705,633 5,209,792 -0-CD OO <3 Total 5,209,792 5,209,792
  10. Treas. Reg. § 1.417(e)-1(d)(7)(v)(B) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    …ayments commencing at age 65 (determined without taking mortality before age 65 into account) is 10.209. (2) Participant T retires at age 60 in 2016 with an accrued benefit of $1,500 per month payable as a straight life annuity commencing at normal retirement age. For benefits commencing at age 60, Plan B provides for …
  11. 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
    …RE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINATION OF LEASED EMPLOYEE STATUS? 208 .01 Scope 209 .02 Employer must request the determination under § 414(n) 209 .03 Forms 209 .04 Employer is responsible for determining continuing status under § 414(n) 209 .05 Pre-approved plans 209 .06 Required information for § …
  12. Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par…
    IRCRevenue ProceduresModified Aug 2, 2021
    …S 208 .01 VCP pre-submission conference 208 .02 VCP requirements 208 .03 Identification of failures 209 .04 Effect of VCP submission on examination 209 .05 No concurrent examination activity 209 .06 Determination letter applications not related to a VCP submission 209 .07 Processing of submission 209 .08 Compliance sta…
  13. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  14. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  15. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …n conference 208 .08 Under limited circumstances, may schedule a conference to be held by telephone 209 SECTION 29. WHAT EFFECT WILL A LETTER RULING HAVE? 209 .01 Has same effect as a determination letter 209 .02 Will not apply to another taxpayer 209 .03 Will be used by the Service in examining the taxpayer’s return 2…
  16. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    IRCCourt RulingsSep 30, 1991related by meaning
    eems that sale to be a prohibited transaction for purposes of the section 4975(a) excise tax which is not excused by any applicable exception. OPINION Section 4975, as added to the Internal Revenue Code by Title II of the Employee Retirement Income Security Act of 1974. imposes an excise tax on prohibited transactions.…
  17. Rev. Proc. 2016-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the …
    IRCRevenue ProceduresJan 4, 2016
    …LETTERS? 208 .01 Scope 208 .02 Qualified trusteed plans 208 .03 Qualified nontrusteed annuity plans 209 .04 Complete information required 209 .05 Complete copy of plan and trust instrument required 209 .06 Section 9 of Rev. Proc. 2016–4 applies 209 .07 Separate application required for each single § 414(l) plan 209 .08…
  18. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  19. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997★ strong match
    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…
  20. 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…