IRCCourt RulingsJul 14, 2005★ strong match
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T.C. Memo. 2005-173
UNITED STATES TAX COURT
TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 1188-01. Filed July 14, 2005.
Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens,
for petitioner.
Jack Forsberg,…
84 FR 59230 — Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements IRCFinal Rules (FR)Nov 1, 2019
…pursuant to § 3.172(d) is subject to the supplementary leverage ratio disclosure requirement at § 3.173(a)(2). (e) A Category III national bank or Federal savings association that is required to calculate a countercyclical capital buffer pursuant to § 3.11 is subject to the disclosure requirement at Table 4 to § 3.173,…
IRCProposed Rules (FR)Proposed Oct 14, 2016
…tion, in accordance with § 159.9(d), in addition to the notice specified in § 159.9(c)(2)(ii).
PART 173—ADMINISTRATIVE REVIEW IN GENERAL 6. The general authority citations for part 173 continues to read as follows:
Authority:
19 U.S.C. 66, 1501, 1520, 1624.
7. Revise § 173.4a to read as follows:
§ 173.4a
Refund of exce…
Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division… IRCRevenue ProceduresJan 2, 2018
…Review of determination letters
172
SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER?
173
.01 Scope of this section
173
.02 Scope of determination letters
173
.03 Design-based safe harbor
173
.04 Governmental plans under § 414(d)
173
.05 Church plans under § 414(e)
173
89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24 ERISAFinal Rules (FR)Apr 25, 2024
…ndent Producer and two hours for a legal professional at an insurer, resulting in an hour burden of 173,535 hours and an equivalent cost of $28.7 million.[106]
Table 14—Hour Burden and Equivalent Cost Associated With the Recordkeeping Requirement
Activity
Year 1
Subsequent years
Burden hours
Equivalent burden cost
Burd…
IRCFinal Rules (FR)Dec 12, 2016
…ation, in accordance with § 159.9(d), in addition to the notice specified in § 159.9(c)(2)(i). PART 173—ADMINISTRATIVE REVIEW IN GENERAL
6. The general authority citation for part 173 continues to read as follows:
Authority:
19 U.S.C. 66, 1501, 1520, 1624.
7. Revise § 173.4a to read as follows:
§ 173.4a
Refund of exces…
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020
…d the request
172
.05 Pending letter ruling requests
172
.06 When to attach letter ruling to return
173
.07 How to check on status of request
173
SECTION 7. WHAT ACTIONS ARE TAKEN IF A REQUEST IS WITHDRAWN OR EMPLOYEE PLANS RULINGS AND AGREEMENTS DECLINES TO ISSUE A LETTER RULING OR DETERMINATION LETTER?
173
.01 In gen…
IRCCourt RulingsFeb 22, 1999related by meaning
112 T.C. No. 6
UNITED STATES TAX COURT
GIDEON L. MEDINA AND CORAZON P. MEDINA, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18999-97. Filed February 22, 1999.
H and W, who were both disqualified persons within
the meaning of sec. 4975, I.R.C., borrowed $340,000
from the qualified pension plan…
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019
…)
172
.05 Church plans under § 414(e)
172
.06 Tax treatment of certain contributions under § 414(h)
173 .07 Other limits on scope of determination letter
173
.08 Leased employees
173
.09 Partial terminations
173
.10 Publication 794, Favorable Determination Letter
173
SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUES…
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
.
Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2022
…BLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS?
173
.01 In general
173
.02 Letter ruling
173
.03 Closing agreement
173
.04 Determination letter
173
.05 Opinion letter
173
.06 Oral advice
174
.07 Nonbank trustee approval letters
174
.08 Compliance statement
175
.09 Adv…
IRCCourt RulingsJan 14, 2013related by meaning
ALS
T.C. Memo. 2013-10
UNITED STATES TAX COURT
THOUSAND OAKS RESIDENTIAL CARE HOME I, INC., ET AL.,' Petitioners
V.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1448-10, 1480÷10, Filed January 14, 2013.
1481-10.
R determined that a corporation's compensation packages for its
owner-employees were unreasonabl…
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…
Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t… IRCRevenue ProceduresSuperseded Jan 4, 2021
….03 Chief Counsel
172
.04 Determination letters not issued for requests for minimum funding waivers
173
SECTION 6. WHAT ARE THE GENERAL INSTRUCTIONS FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS?
173
.01 In general
173
Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023
…evenue procedure
169
.04 Updated annually
172
.05 Possible future updates related to Appeals review
173
SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2022-4?
173
.01 In general
173
.02 Changes made to Revenue Procedure 2022-4
173
PART I. GENERALLY APPLICABLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PR…
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…
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 …
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 RulingsJun 1, 1987related by meaning
transaction on the first day of each taxable year or portion of a taxable year within the taxable period until corrected on May 10, 1982, was proper. Based on our determinations herein,
Decision will be entered for the respondent.
Unless otherwise indicated, all section references are to the Internal Revenue Code of 1…
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., …