89 FR 12955 — Management of Federal Agency Disbursements IRCFinal Rules (FR)Feb 21, 2024
ement as subparagraph (b) and designating the existing language in 208.7 as subparagraph (a).
Section 208.8
We are not amending § 208.8.
Section 208.9 We are amending § 208.9(b) to clarify that when an agency fails to make a payment by EFT as prescribed by this part 208 and no waiver under § 208.4 is applicable, Treasu…
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…
75 FR 44656 — Registration of Mortgage Loan Originators IRCFinal Rules (FR)Jul 28, 2010
…(j), 1828(o), 1831, 1831o, 1831p-1, 1831r-1, 1831w, 1831x, 1835a, 1882, 2901-2907, 3105, 3106a(1), 3108(a), 3310, 3331-3351, and 3906-3909, 5101 et seq.,15 U.S.C. 78b, 78l(b), 78l(g), 78l(i), 78o-4(c)(5), 78q, 78q-1, 78w, 1681s, 1681w, 6801 and 6805; 31 U.S.C. 5318, 42 U.S.C. 4012a, 4104a, 4104b, 4106, and 4128.
2. Sub…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsJun 4, 2014related by meaning
must decide whether the Court has jurisdiction to review respondent's
whistleblower claim award determination where the claim is based on information the whistleblower provided both before and after the enactment of TRHCA sec.
406, 120 Stat. at 2958.9 ¹°
I. Overview of the Court's Jurisdiction and the Whistleblower Pr…
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
…of determination letters
207
.03 Design-based safe harbor
207
.04 Governmental plans under § 414(d)
208
.05 Church plans under § 414(e)
208
.06 Tax treatment of certain contributions under § 414(h)
208
.07 Other limits on scope of the determination letter
208
.08 Affiliated service groups, leased employees and partial …
IRCCourt RulingsSep 15, 2005related by meaning
125 T.C. No. 5
UNITED STATES TAX COURT
SERVICE EMPLOYEES INTERNATIONAL UNION,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent
100 OAK STREET CORPbRATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 .
saan.
Ps are qualified labor. organi…
IRCCourt RulingsAug 26, 1963related by meaning
422, 441.
Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsFeb 9, 2023related by meaning
. This
1971 revision contained the same text of sections 1.482-1 and-2 that
appeared in the 1970 revision. 26 C.F.R. sec s . 1.482- 1, - 2 (1971). The text of section 1.4 82- 1 appears at 288- 292 of the relevant volume of the
1971 revision to the Code of Federal Regulations. 26 C.F.R. sec. 1.482-1 (1971).
FF. Commissi…
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…
IRCCourt RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Dec 30, 2024
loyer must request the determination under § 414(n)
208
.03 Forms
208
.04 Employer is responsible for determining continuing status under § 414(n)
208 .05 Pre-approved plans
208
.06 Required information for § 414(n) determination
208
SECTION 18. WHAT ARE THE PROCEDURES FOR REQUESTING § 401(h) AND § 420 DETERMINATION LE…
IRCCourt RulingsAug 31, 1978related by meaning
ioner for the purpose of computing its depreciation deductions.
FINDINGS OF FACT
Some of the facts have been stipulated, and those facts are so found. The petitioner in docket No. 8683-74 is 212 Corporation (212 Corp.), which had its principal place of business in Erie, Pa., at the time it filed its petition in this ca…
Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023
… PROCEDURES FOR INDIVIDUALLY DESIGNED MULTIPLE EMPLOYER PLANS (QUALIFIED PLANS ONLY)?
207
.01 Scope
208
.02 Applicant must request letter for plan in the name of the controlling member
208
.03 Where to file requests
208
.04 Addition of employers
208
SECTION 15. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMI…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
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
… prior to time for amending for change in law
207
.06 Restatement not required for terminating plan
208
SECTION 16. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR GROUP TRUSTS?
208
.01 Scope
208
.02 Required information
208
.03 Forms
208
SECTION 17. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINAT…
IRCCourt RulingsAug 7, 2008related by meaning
al tax under
section 72 (t) .
In reaching our holdings herein, we have considered al l
arguments made by the parties-, and to the extent not mentioned above, we find them to be irrelevant or without merit .
To reflect the foregoing,
Decision will be entere d
for respondent .
IRCCourt RulingsFeb 24, 2016
… as a conduit or an
agent in arranging the transfer. They rely on Lashells' Estate v. Commissioner,
208 F.2d 430 (6th Cir. 1953), aff'g in part, rev'g in part 11 T.C.M. (CCH) 274
(1952), and Shaara v. Commissioner, T.C. Memo. 1980-247. Both Lashells'
Estate and Shaara involved similar facts.¹7 The taxpayers received pa…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …