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80 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 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…
  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. 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…
  4. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
  5. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    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…
  6. 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 …
  7. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    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…
  8. 40 T.C. 882 — New York Post Corp. v. Commissioner
    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 …
  9. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
  10. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  11. 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…
  12. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    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…
  13. 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…
  14. 70 T.C. 788 — 212 Corp. v. Commissioner
    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…
  15. 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…
  16. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    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…
  17. 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…
  18. T.C. Summary Opinion 2008-98 — Ashwani K. & Sveltlana K. Sharma v. Commissioner
    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 .
  19. T.C. Memo. 2016-29 — Mark Vandenbosch & Julie Vandenbosch v. Commissioner
    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…
  20. 45 T.C. 133 — Jacobs v. Commissioner
    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 …