IRCCourt RulingsJan 31, 1973
… year for previously accrued sick leave referred to as “nonforfeitable” accrued sick leave and $113,851 of “for-feitable” sick leave accrued which petitioner would have to pay during the ensuing year unless the employee voluntarily quit or was discharged for dishonesty. To compute the total of $202,696 petitioner subtr…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
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 11, 2003related by meaning
h the “objective of the safe
harbor provision” referred to by the Court of Appeals in Evans
Cooperage
. Petitioner’s failure to file a return prior to respondent’s issuance of the notice presents us with a situation
that is the exact opposite of that referred to in Evans
Cooperage
, where the filing of returns preceded…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
… Business
Income
185,430 – – – – –
SE AGI Adjustment (6,949) (8,563) (15,922) (17,098) (13,132) (10,851)
Itemized Deductions 9,092 (18,205) (9,895) (11,281) (18,675) ( 13,108)
IRCCourt RulingsMay 27, 2004related by meaning
is liable for the
second-tier excise tax under section 4975(b). We note, however,
- 19 -
that sections 4961(a) and 4963(e)(1) generally allow for the abatement of a second-tier excise tax if the prohibited
transaction giving rise thereto is corrected within 90 days after
our decision sustaining the tax becomes final. …
IRCCourt RulingsSep 13, 1990
…the trust's assets and the marital deduction amount. The marital deduction amount is equal to $ 458,851. ($ 858,851, the value of decedent's share of the trust's assets, reduced by $ 400,000, the amount needed to fully utilize the $ 121,800*92 of unified credit available to the estate, equals a marital deduction amount…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…5
$7,440,454
46,695 $7,440,454
Senior Executive Staff
68,156
12,992,578
68,156
12,992,578
Total
114,851
20,433,032
114,851
20,433,032
( printed page 75998)
1.6 Costs Associated With Written Policies and Procedures
Under the original exemption, financial institutions were already required to maintain their policies and …
81 FR 83137 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Nov 21, 2016
…From—
To—
2018
631
631
2,665
2,665
2019
645
645
2,724
2,724
2020
660
660
2,787
2,787
2021
675
675
2,851
2,851
2022
691
691
2,916
2,916
2023
707
707
2,983
2,983
2024
723
723
3,052
3,052
2025
740
740
3,122
3,122
2026
757
757
3,194
3,194
2027 or later
774
774
3,268
3,268
1
Table II-A.
2
Table II-B.
3
Table II-C.
( prin…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
75 FR 64197 — Additional Rules Regarding Hybrid Retirement Plans IRCProposed Rules (FR)Proposed Oct 19, 2010
…mined by reference to a rate of return on a regulated investment company (RIC) described in section 851. The preamble focused on whether such an investment has sufficiently constrained volatility that the existence of the capital preservation rule would not result in an above market rate of return. In response to comme…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…ue of the property purchased.
(42) Section 679.—See sections 4.01(39) and (40), above.
(43) Section 851.—Definition of Regulated Investment Company.—Any issue relating to the treatment of a corporation as a regulated investment company under § 851 and related provisions that requires a determination whether a financial…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
- 8 -
[…
IRCCode / StatuteJan 6, 2025
… means a domestic corporation which is a regulated investment company within the meaning of section 851(a).
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCRegulationsMay 18, 2016
…directly as part of a broader fund that is— (1) A regulated investment company described in section 851(a); (2) A common or collective trust fund or pooled investment fund maintained by a bank or trust company supervised by a State or a Federal agency; (3) A pooled investment fund of an insurance company that is qualif…
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
IRCCourt RulingsMar 20, 1997★ strong match
…
only one of several considerations. Rose v. Commissioner
, 88
T.C. 386, 410 (1987), affd. 868 F.2d 851 (6th Cir. 1989).
The U.S. Court of Appeals for the Ninth Circuit, the circuit
in which this case is appealable, Golsen v. Commissioner
, 54 T.C.
742 (1970), affd. 445 F.2d 985 (10th Cir. 1971), determines
whether a t…
IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…