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74 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  2. 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…
  3. 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…
  4. 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…
  5. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    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…
  6. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  7. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    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,…
  8. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    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 …
  9. 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 .
  10. T.C. Summary Opinion 2004-1 — Lawrence K. Mudd v. Commissioner
    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…
  11. 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%)…
  12. 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…
  13. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    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…
  14. 73 T.C. 40 — La Fargue v. Commissioner
    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…
  15. 80 T.C. 239; 80 T.C. No. 4 — Feichtinger v. Commissioner
    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…
  16. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  17. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    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…
  18. 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 …
  19. 98 T.C. 283; 98 T.C. No. 23 — Aronson v. Commissioner
    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…
  20. 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 …