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…
IRCCourt RulingsFeb 9, 2023related by meaning
ement of this title, including all rules and regul ations as may be
necessary by reason of any alteration of law in relation to internal
revenue.”
108 Section 7805(b) of the Internal Revenue Code of 1954, 68A Stat.
at 917, was the provision in the Internal Revenue Code of 1954 that was
analogous to section 3791(b) of t…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
88 FR 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges IRCFinal Rules (FR)Dec 21, 2023
…partments estimate that certified IDR entities collect a certified IDR entity fee for approximately 135,000 disputes annually.[131]
Therefore, for the purposes of this analysis, the Departments estimate that certified IDR entities will collect certified IDR entity fees for approximately 94,500 single disputes and 40,50…
IRCCourt RulingsOct 10, 2018
…the Court apply the framework from Dalton v. Commissioner, 682 F.3d 149,
157 (1st Cir. 2012), rev'g 135 T.C. 393 (2010) and T.C. Memo. 2011-136, to this
IRCRegulationsSep 9, 2016
…t from mid-year) 143,500 5. Unfunded liability as of 12/31/76: item 1 + item 2 + item 3 −item 4 907,393 (B) Computation of the Outstanding Balance of the Bases as of December 31, 1976 1. Original base: ($900,850−$50,000) × 1.05 $893,393 2. Shortfall loss $30,000 × 1.05 31,500 3. Total 924,893 (C) Computation of the Cre…
89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit IRCFinal Rules (FR)Dec 11, 2024
…% of the basis pool, or $105, was attributable to the remittance. The amount of the remittance was $135 (€100 translated at the spot rate on June 30, year 3, of €1 = $1.35). Therefore, in year 3, DC recognized section 987 gain of $30, equal to the difference between the amount of the remittance ($135) and the portion o…
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
…% of the basis pool, or $105, was attributable to the remittance. The amount of the remittance was $135 (€100 translated at the spot rate on June 30, year 3, of €1 = $1.35). Therefore, in year 3, DC recognized section 987 gain of $30, equal to the difference between the amount of the remittance ($135) and the portion o…
IRCCourt RulingsApr 2, 2020
quirements of section 7121. See Urbano v.
Commissioner, 122 T.C. at 393-394.
Section 7121 and the regulations thereunder set forth the exclusive means and procedures by which an agreement between the IRS and a taxpayer concerning
the latter's tax liability may be accorded finality. See, e.g., Urbano v.
Commissioner, 12…
IRCCourt RulingsApr 11, 2012related by meaning
ices." Sec. 1.61-1(a), Income Tax Regs. However, section 301 provides
that funds (or any other property) distributed by a corporation to a shareholder over which the shareholder has dominion and control are to be taxed under the
provisions of section 301(c).
"Under section 301(c), a constructive distribution is taxable…
IRCCourt RulingsApr 16, 2020
…89 --- 2,489
Travel 2,456 2,456 --- 2,456
Taxes and licenses 15,317 15,317 15,317 ---
Rent/lease 21,135 21,135 21,135 ---
IRCCourt RulingsSep 13, 1990related by meaning
y [section 403(a) of ERTA],
then the amendment made by [section 403(a) of ERTA] shall not apply to the estate of such decedent.
[1981-2 C.B. 326-327.] *295 Respondent asserts that all the conditions contained in section 403(e)(3) have been met. Therefore, *99 he maintains, petitioner is not entitled to an unlimited mar…
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
.
88 FR 65888 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges IRCProposed Rules (FR)Proposed Sep 26, 2023
artments assume that certified IDR entities collect a certified IDR entity fee on approximately 135,000 of those 225,000 closed disputes annually.[89] Therefore, for the purposes of this analysis, the Departments estimate that certified IDR entities would collect certified IDR entity fees on approximately 94,500 single…
IRCCourt RulingsMar 20, 2006
… from another
custodian."
During 2001, petitioner received IRA distributions from
Janus of $19.86, $393.19, $5,410.13, and $3,966.76. Janus sent
- 3 -
petitioner Forms 1099-R, Distributions From Pensions, Annuities,
Retirement or Profit-Sharing Plans, IRAs, Insurance: Contracts,
etc., for these distributions. The Forms…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
ERISACode / StatuteJan 6, 2017
…agraph (B), subsection (a) shall not apply to the Hawaii Prepaid Health Care Act (Haw. Rev. Stat. §§393–1 through 393–51).
(b)(5)(B) (B) Nothing in subparagraph (A) shall be construed to exempt from subsection (a)—
(b)(5)(B)(i) (i) any State tax law relating to employee benefit plans, or
(b)(5)(B)(ii) (ii) any amendmen…
IRCCourt RulingsJul 13, 1995related by meaning
ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
IRCCourt RulingsDec 5, 2007
…to reduced paid-up insurance retroactively
effective to December 28, 1997, with a face value of $34,135 . On
September 30, 2003, MetLife confirmed to Ms . Quinn that she was
the owner of the Ms . Quinn policy and that the policy was being
continued as reduced paid-up insurance in the amount of $34,135,
which would incr…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…