IRCCourt RulingsFeb 9, 2023related by meaning
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
IRCCourt RulingsAug 13, 1990related by meaning
agreement requires 60 days’ notice, respondent did not issue statutory notices until December 1, 1987, more than 60 days after the date of the letter. Moreover, that respondent did not comply, in exact detail, with his own internal operating procedures does not affect the resolution of the issue presented by petitioner…
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…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…,085. HHS assumes that 80 percent of individual physician practitioners have a website resulting in 116,709 websites needed to be updated with good faith estimate notices. HHS assumes that the physician will pay a computer programmer to make the website update. The burden is estimated as follows: 116,709 websites needi…
IRCCourt RulingsSep 13, 2017
bee v.
Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner meets his
burden of production, the taxpayer bears the burden of proving, through persuasive evidence, that the Commissioner's penalty determination is incorrect.
S_e_e Rule 142(a); Welch v. Helvering, 290 U.S. at 115; Higbee v. Commissioner,
116 T.C.…
77 FR 5632 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Feb 3, 2012
…
286,000
Investment Disclosure
8,929,000
1,210,000
1,210,000
3,783,000
Update Investment Disclosure
116,000
116,000
116,000
116,000
Investment Disclosure Total
9,045,000
1,326,000
1,326,000
3,899,000
Notice 2022-45 — Notice 2022-45 extends the deadlines for amending an eligible retirement plan (including an individual retirement arrangement or annuity contract) to reflect t… IRCNoticesOct 17, 2022
…t the provisions of section 2202 of the Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136, 134 Stat. 281 (2020) (CARES Act), and section 302 of Title III of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 (Relief Act), enacted as Division EE of the Consolidated Appropriations Act, 2021, Pub…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
o calculate current liability and to determine the required contribution are set forth.
EXEMPT ORGANIZATIONS
Announcement 2006-55 Announcement 2006-55 Aviation Safety Council, Inc., of Pasadena, CA; Budget and Credit Counseling Services, Inc., of New York, NY; and Mason Credit Counseling, Inc., of Hauppauge, NY, no lon…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
T.C. Memo. 2017-77 — Estate of Hung-Liang Lynn Lin, Deceased, Jeffrey S. Lin, Administrator v. Commissioner IRCCourt RulingsMay 8, 2017
…taxpayer acted in good faith with respect to such portion.
Sec. 6664(c)(1); Higbee v. Commissioner, 116 T.C. at 446-447. The
determination of whether the taxpayer had reasonable cause and acted in good
faith depends upon the pertinent facts and circumstances of a particular case. Sec.
1.6664-4(b)(1), Income Tax Regs. W…
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
IRCCourt RulingsDec 2, 1981related by meaning
…n, 94th Cong., 2d Sess., General Explanation of the Tax Reform Act of 1976,1976-3 C.B. (Vol. 2) 413^116.
Respondent’s answer in each one of those cases was filed on Mar. 6,1981. Rule 38.
U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner IRCCourt RulingsDec 13, 2018
…le, they had reasonable cause and acted in good faith. See sec. 6664(c)(1); Higbee v.
Commissioner, 116 T.C. at 446-447.
The determination whether the taxpayer had reasonable cause and acted in
good faith depends upon the pertinent facts and circumstances of a particular case.
Sec. 1.6664-4(b)(1), Income Tax Regs. We c…
85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency IRCFinal Rules (FR)Nov 6, 2020
…n-6008-faqs.pdf (Updated April 13, 2020)
Families First Coronavirus Response Act (FFCRA),Public Law 116-127 Coronavirus Aid, Relief, and Economic Security (CARES) Act, Public Law 116-136 Frequently Asked Questions (FAQs) available at
https://www.medicaid.gov/state-resource-center/downloads/covid-19-section-6008-CARE…
IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
IRCCourt RulingsOct 3, 1995related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTE…
IRCCourt RulingsOct 25, 2006
return, petitioner properly
reported the $116,251 .20 distribution as income but did not
report the 10-percent additional tax for early distributions under section 72(t) . In the notice of deficiency, respondent
determined that petitioner was liable for the 10-percent
additional tax on the early $116,251 .20 distribut…
IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
IRCCourt RulingsJan 3, 2017
is
appropriate. See sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446
(2001). Once the Commissioner meets his burden of production, the taxpayer bears the burden of proving, through persuasive evidence, that the
Commissioner's penalty determination is incorrect. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, …
IRCCourt RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…