86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
ccurring after CMS's notice under § 150.307, § 150.313(e), or § 150.505.
41. Section 150.455 is amended by adding paragraph (b)(9) to read as follows: § 150.455
Sanctions.
* * * * *
(b) * * *
(9) In the case of a violation of part 149 of this subchapter, ordering the party or attorney to pay attorneys' fees and other c…
IRCRegulationsJul 26, 2016related by meaning
8 9 9 10 42 6 6 6 7 7 8 9 9 10 11 43 6 7 7 8 8 9 9 10 11 12 44 7 7 8 8 9 10 10 11 12 13 45 7 8 8 9 10 10 11 12 13 14 46 8 9 9 10 11 11 12 13 14 15 47 9 9 10 11 12 12 13 14 15 16 48 9 10 11 12 13 14 15 16 17 18 49 10 11 12 13 14 15 16 17 18 19 50 11 12 13 14 15 16 17 18 20 21 51 12 13 14 15 16 17 19 20 21 22 52 13 14 15…
78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property IRCFinal Rules (FR)Sep 19, 2013related by meaning
e tires) as 3-year property and the tractor tires as 5-year property under section 168(e). Because R's tractor is property other
( printed page 57723) than a building, the initial units of property for the tractor are determined under the general rule in paragraph (e)(3)(i) of this section and are comprised of all the …
IRCCourt RulingsFeb 9, 2023related by meaning
. . . . . . . . . . . . . . . . . . . . . . . . 5%
7. Basic Chemicals . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5%
8. Heavy Metallurgy 01 --Iron and Steel . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5%
02 --Aluminum . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5%
9. Electric…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
…asis pool attributable to the distribution. For this purpose, the capital equity pool was equal to €150, and the capital basis pool was equal to $150, as shown below:
Table 4 to Paragraph (
l
)(2)(
i
)(C)(
2)—Capital Equity and Basis Pools
Equity pool
Translation rate
Basis pool
Contribution (6/30/Year 1)
€150
€1 = $…
IRCCourt RulingsJan 29, 2019related by meaning
$1,875, but that the amount is limited to $1,500 pursuant to
section 25C(b).
Petitioner introduced at trial (1) an invoice from Crums Climate Control, Inc. (invoice), dated April 28, 2009, and (2) a Certificate of Product Ratings by the
Air-Conditioning, Heating, and Refrigeration Institute (AHRI certificate) dated
Oct…
IRCCourt RulingsMar 7, 2019related by meaning
$1,175 163 98 59 59 29 Concedes
Equipment--Krom. 4/15/2003 7,000 7,000 -- -- -- A
Equipment--Henn. 6/18/2003 15,825 15,825 -- -- -- A
4630 Equipment-- Cherokee 7/15/2003 15,000 15,000 -- -- -- -- -- B
Equipment--Henn. 7/23/2003 3,200 3,200 -- -- -- B
TC Equipment--
Henn. 8/1/2003 13,750 13,750 -- -- -- -- -- B
Equipmen…
T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover … IRCTreasury DecisionsMar 23, 2009related by meaning
to excess aggregate contributions is determined under §1.401(m)-2(b)(2)(iv) (as it appeared in the April 1, 2007, edition of 26 CFR part 1).
* * * * * (vi) Tax treatment of corrective distributions—(A) Corrective distributions for plan years beginning on or after January 1, 2008. Except as otherwise provided in this pa…
IRCCourt RulingsJun 9, 1965related by meaning
Fuel___ Miscellaneous deferred charges_ 5,003.87 5,607.00 2,438.14 5,003.87 5,607.00 2,438.14
Total deferred charges. 13,049.01 13,049.01
FIXED ASSETS Land. Building (net)...— Railway siding (net)..... Driveway and parking lot (net).... Machinery and equipment (net).... Office furniture and fixtures (net)... Office mac…
IRCCourt RulingsMay 12, 1971related by meaning
g $1,000,
may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a). Harold and Caroline reported $10,224.57 as long-term capital gain in. 1964 and $30,673.70 as long-term capital gain in each subsequent year. Assuming that the annual pay…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014
lowing year. On December 31, 2016, H has an involuntary separation from service. S pays H $150,000 on January 1, 2017 and $150,000 on January 1, 2018. (ii) Pursuant to paragraph (d)(6) of this section, involuntary separation pay may be attributed to services performed by H in the taxable year of S in which the involunt…
IRCRegulationsJul 12, 2016
…her it is denied exemption. Y's grass roots expenditures for 1977 and 1978 ($65,000) did not exceed 150 percent of the sum of its grass roots nontaxable amounts for those years ($103,125). Y's lobbying expenditures for 1977 and 1978 ($406,750) did not exceed 150% of its lobbying nontaxable amount for those years (150% …
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…
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
…asis pool attributable to the distribution. For this purpose, the capital equity pool was equal to €150, and the capital basis pool was equal to $150, as shown in the table below. Because Branch distributed 33% of the capital equity pool, or €50, 33% of the capital basis pool, or $50, was attributable to the distributi…
IRCPrivate Letter RulingsDec 2, 2005related by meaning
- -
- - -
IRCCourt RulingsJun 18, 1959related by meaning
equipment, and all other miscellaneous buildings and equipment used only in connection with the excavation and transportation of ore from the mine. 2. The purchase price of said concentrating plant shall be the sum of Fifty thousand ($50,000.00) Dollars, payable in monthly installments on the following basis, and at th…
IRCCourt RulingsMay 4, 1978related by meaning
angery .93.16'
Miller’s .104.95
Franklin Optical .33.80
Lowenstein Bros .106.00
569.04
$39.95 to Lowenstein Bros.
$16.25 to Maxey’s Boat Dock for gas. $83.44 to Hub Clothiers for winter clothing.
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
.
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…