IRCCourt RulingsJul 14, 2005related by meaning
…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 (1992),
affd. 16 F.3d 75 (5th Cir. 1994). "Is…
85 FR 76976 — Guidance Clarifying Premium Tax Credit Unaffected by Suspension of Personal Exemption Deduction IRCFinal Rules (FR)Dec 1, 2020
…ents to the Income Tax Regulations (26 CFR part 1) under sections 36B and 6011 of the Code. Section 151 of the Code generally allows a taxpayer to claim a personal exemption deduction, based on the exemption amount defined in section 151(d), for the taxpayer, the taxpayer's spouse, and any dependents, as defined in sec…
Notice 2018-84 — Notice 2018–84 provides interim guidance clarifying how the suspension of the personal exemption deduction in § 151(d)(5) of the Tax Cuts and Jobs Act applies … IRCNoticesNov 5, 2018
… the exemption amount, and entering that amount on the tax return. Section 11041 of the Act added § 151(d)(5) to the Code. Section 151(d)(5)(A) provides that, for taxable years beginning after December 31, 2017, and before January 1, 2026, the term “exemption amount” means zero. Section 151(d)(5)(B) provides that the r…
85 FR 31710 — Guidance Clarifying Premium Tax Credit Unaffected by Suspension of Personal Exemption Deduction IRCProposed Rules (FR)Proposed May 27, 2020
…ents to the Income Tax Regulations (26 CFR part 1) under sections 36B and 6011 of the Code. Section 151 of the Code generally allows a taxpayer to claim a personal exemption deduction, based on the exemption amount defined in section 151(d), for the taxpayer, the taxpayer's spouse, and any dependents, as defined in sec…
IRCCourt RulingsJan 14, 2013★ strong match
… Valley Estates, Inc. v.
Commissioner, 99 T.C. 379 (1992), aff'd in part, remanded in part, 49 F.3d 1410
(9th Cir. 1995). Because we found supra that a portion of TORCH's contributions to
the pension plan was unreasonable compensation and therefore not deductible under
section 162 (and thereby section 404), the 10% sec…
IRCCourt RulingsFeb 9, 2023★ strong match
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsFeb 22, 1989related by meaning
…FRA; we treat this as, in effect, a concession by respondent. See subparagraphs (4) and (5) of Rule 151(e); Money v. Commissioner, 89 T.C. 46, 48 (1987).
We conclude that, for purposes of the instant case (see C. Alternative Consideration, infra), the Judicial Plan is a qualified State judicial plan.
We have concluded,…
IRCCourt RulingsOct 10, 2018
13
C T
151 T.C. No. 9
UNITED STATES TAX COURT
DAVID H. MELASKY AND AUDREY MELASKY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12777-12L. Filed October 10, 2018.
This CDP case involves Ps' 2006, 2008, and 2009 income tax
liabilities. Ps gave R a check which they asked to have applied
against …
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 RulingsJan 8, 2004
… dependency
exemption deduction with respect that individual is allowable to
another taxpayer. Sec. 151(d)(2). Amy. Amy was a full-time student at the University of Kentucky
during 1996, and during that year she turned 20 or 21 years old.
Petitioner and respondent have framed this issue to be
whether Amy claimed a pers…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…n is estimated as: [(395 small broker-dealers + (2,996 small registered-investment advisers × 8%) + 151 small insurers + 10 small robo-advisers + 930 small pension consultants + 20 small investment company underwriters) × 10% × 5 hours] + [(1,499 large broker-dealers + (12,986 large registered-investment advisers × 8%)…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…ties section.
Back to Citation
737. This is estimated as: (500,000 Retirement Investors × 28.2%) = 141,000 paper disclosures. Note, the total values may not equal the sum of the parts due to rounding.
Back to Citation
738.
This is estimated as: (141,000 paper disclosures × (2 minutes ÷ 60 minutes)) = 4,700 hours. A l…
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
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…
IRCCourt RulingsJan 20, 1983related by meaning
sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
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…
IRCCourt RulingsJun 17, 1997
…-0-55,000-0 - - 0 - - 0 -
Policy values-0-96,219 149,983 160,176 169,181
Surrender value N/A 90,412 141,438 151,632 160,636
Additional contrib. available 3,976 4,263 15,647 23,058 35,386
Date of report 08/12/91 09/14/92 02/23/94 12/08/94 01/16/96
E. Forms 5500-C/R
Forms 5500-C/R for N.L. Booth's account in the Prime Pl…
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 RulingsMar 18, 1992
… interest income from Baltimore Federal Financial Services in the amounts of $53 and $88 (totaling $141). In the notice of deficiency, respondent increased petitioners' interest income by $151. Respondent agrees that the omitted interest income was $141 rather than $151 as determined in the notice of deficiency.
Sec. 4…
81 FR 13305 — Definition of Political Subdivision; Correction IRCProposed Rules (FR)Proposed Mar 14, 2016
…ations of a political subdivision under section 103 but also for other purposes of sections 103 and 141 through 150. Commenters explained that, without a transition rule for the private activity bond rules under section 141, certain bonds issued before the notice of proposed rulemaking and notice of public hearing was …