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…
88 FR 54511 — Request for Information-SECURE 2.0 Reporting and Disclosure ERISAProposed Rules (FR)Proposed Aug 11, 2023
E 2.0 requires the Department to issue regulations implementing the requirements under section 113 of ERISA not earlier than one year after enactment. Further, these regulations must contain a model disclosure reflecting the content requirements under section 113 that plan administrators may use to discharge their stat…
Notice 2010-80 — This notice provides additional relief for nonqualified deferred compensation plans covered under section 409A. This notice also expands the types of plans eli… IRCNoticesDec 20, 2010
…d Employee SS treat the commencement of payment in 2011 as an operational failure under Notice 2008-113, and such failure is eligible to be corrected, and is actually corrected as an impermissible payment in accordance with Notice 2008-113, Employee SS is not required to include any amount in income under § 409A(a) sol…
Ann. 2015-13 — This announcement explains the effect of H.R. 2591, which became Public Law 113–243. The announcement also explains how taxpayers should report the rollover of… IRCAnnouncementsApr 13, 2015
Announcement 2015–13
Reporting Airline Payment Amount Rollovers Under Public Law 113–243
PURPOSE
This announcement explains how taxpayers must report rollovers of airline payment amounts under recently enacted Public Law 113–243 (“P.L. 113–243”), which amended certain provisions of the FAA Modernization and Reform Act …
IRCCourt RulingsFeb 22, 1989related by meaning
ate for respondent to change his position 6 months after the start of the trial and after all of petitioners’ witnesses had completed their testimony. On brief, respondent continues to argue section 131(c)(3)(B)(ii)(I) of R.A. 1978, as amended by section 252 of TEFRA; we continue to refuse to consider that argument in …
IRCCourt RulingsJun 4, 2014related by meaning
hey would establish that respondent proceeded against the targets using
information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's
award determination.
We hold, consistent with the rationale of Dacosta, that this Court…
IRCCourt RulingsJan 13, 2003
odial parent. Sec. 152(e)(2).
more than half of whose support during the calendar year is
provided for by the taxpayer, are “dependents”. Sec. 152(a). Section 152(e)(1), however, further provides that if a child
receives more than half of his support during the calendar year
from parents who are divorced or legally sep…
T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.… IRCTreasury DecisionsApr 30, 2007
…date. In this case, the straight life annuity payable under the plan commencing at the same age is $152,619. Because the plan’s factors for actuarial equivalence in this case are the same standardized actuarial factors required to be applied to determine the actuarially equivalent straight life annuity, the actuarially…
REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie… IRCProposed Rules (FR)Proposed Jul 5, 2005
…able. In this case, the straight life annuity payable under the plan commencing at the same age is $152,619. Because the plan’s factors for actuarial equivalence in this case are the same standardized actuarial factors required to be applied to determine the actuarially equivalent straight life annuity, the actuarially…
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017
Rev. Proc. 2017–4
TABLE OF CONTENTS
SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE?
152
.01 Purpose of revenue procedure
152
.02 Organization of revenue procedure.
152
.03 Other guidance affecting this revenue procedure
152
.04 Updated annually
152
>SECTION 2. WHAT CHANGES HAVE BEEN MADE TO THIS REVENUE PROCE…
IRCRegulationsSep 9, 2016
…date. In this case, the straight life annuity payable under the plan commencing at the same age is $152,619. Because the plan's factors for actuarial equivalence in this case are the same standardized actuarial factors required to be applied to determine the actuarially equivalent straight life annuity, the actuarially…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
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…
IRCRegulationsMay 18, 2016
…use, the service provider's beneficiary, or the service provider's dependent (as defined in section 152, without regard to section 152(b)(1), (b)(2), and (d)(1)(B)); loss of the service provider's property due to casualty (including the need to rebuild a home following damage to a home not otherwise covered by insuranc…
Notice 2010-6 — This notice provides rules governing the taxation of nonqualified deferred compensation plans. Section 409A of the Code requires that a nonqualified deferred c… IRCNoticesModified Jan 19, 2010
100x as an operational failure under Notice 2008-113 and Employee H repays Employer the $100x and meets all the other requirements of Notice 2008-113. Conclusion: Because the plan provision defining disability was corrected and all payments received under the plan due to the impermissible payment event were treated as …
IRCRegulationsNov 17, 2025
…ry education for the employee, for the employee's spouse, child or dependent (as defined in section 152 without regard to section 152(b)(1), (b)(2) and (d)(1)(B)), or for a primary beneficiary under the plan; (4) Payments necessary to prevent the eviction of the employee from the employee's principal residence or forec…
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…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…921
$60,610,921
$60,610,921
Preparation: 2020 Safe Harbor Explanation (Year 1 Only)
$14,586,856
$15,152,730
$0
$15,152,730 Preparation: 2002 Safe Harbor Notice (Year 1 Only)
$6,069,717
$0
$15,152,730
$15,152,730
Add Contact Info: 2020 Safe Harbor Explanation (Year 1 Only)
$4,059,862
$4,224,622
$0
$4,224,622
Add Contact…
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
IRCPrivate Letter RulingsFeb 2, 2018
… (a s defined in
section 213(d)) of the taxpayer, his spouse, his dependents (as defined in section 152,
determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof), and any
child (as defined in section 152(f)(1)) of the taxpayer who as of the end of the taxable
year has not attained age 27. Any chi…