IRCCourt RulingsFeb 9, 2023★ strong match
tax and
administrative matters, issued pursuant to the Internal
revised as of Jan. 1,
1958
Regulations promulgated during 1954-57, and effective as to facts arising on and after Jan. 1, 1958. 26 (pts. 1-19) C.F.R. v
(1958).
revised as of Jan. 1.,
1959
Regulations promulgated during 1954-58, and effective as to
facts ar…
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
…ognized to the extent of gain (other than section 987 gain) recognized in connection with a section 331 liquidation. As explained in part X.B.3 of this Summary of Comments and Explanation of Revisions, the loss-to-the-extent of gain rule generally does not allow suspended section 987 loss to be recognized in excess of …
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…er Documentation:
Total
$878,139
$18,493,989
$19,250,589
$2,048
$460,359
$36,678
Per-Entity
$472
$2,331
$2,331
$29
$46,036
$1,183
Policies:
Total
$1,789,886
$7,232,234
$7,528,108
$76,028
$19,333
$59,932
Per-Entity
$961
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006★ strong match
…02(e)(2) business terminations are not subject to this provision.)
(23) Sections 302(b)(4) and (e), 331, 332, and 346(a).—Effects on Recipients of Distributions in Corporate Liquidations.—The tax effect of the liquidation of a corporation preceded or followed by the transfer of all or a part of the business assets to a…
T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. IRCTreasury DecisionsSep 18, 2006related by meaning
INCOME TAX
Notice 2006-76 Notice 2006-76
This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether i…
IRCCourt RulingsOct 17, 1995
…Utilities 3,837.35 5,503.09 5,503.09 -0Telephone 587.75 -0- 1,342.33 (1,342.33)
Miscellaneous -0- 8,331.42 -0- 8,331.42
Meals -0- -0- 662.73 (662.73)
Depreciation 2,248.00
2,889.00
2,889.00
-0-
Total 20,603.76
37,494.61
28,331.15
9,163.46
Section 62(a)(4) allows the deduction of expenses
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsJul 2, 2002
…alculated a
tax of $17,037 for an early distribution under section 72(t).
Petitioner claimed a $136,331 short-term capital loss from the
sale of the Atascadero property. Petitioner calculated a
$336,331 basis in the property, consisting of $170,371, the
amount owed him by Stephanie and David when he took the deed in
li…
IRCCourt RulingsMay 13, 1965
…en in the latter situation the matter is by no means free from doubt. Cf. United States v. Johnson, 331 F. 2d 943 (C.A. 5); United States v. Peebles, 331 F. 2d 955 (C.A. 5); United States v. Martin, 337 F. 2d 171 (C.A. 8).
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
…not recognized when the owner of a section 987 QBU liquidates in a transaction described in section 331. Proposed § 1.987-13(f). Instead, suspended section 987 loss that is not recognized in the taxable year of the liquidation is eliminated and will never be recognized. This rule is intended to prevent taxpayers from e…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCPrivate Letter RulingsOct 5, 2012
…not legal nicety of title, determine tax
ownership. For example, in Helvering v. Clifford, 309 U.S. 331, 60 S.Ct. 554, 84 L.Ed.
15
It is intended that these investments will at least equal the SIV of all contracts at any point in t ime but they will not match the HAB. Moreover, only
the SMV and SIV, as applicable, dete…
IRCCourt RulingsNov 21, 2007
… the year, petitioner
caused Norwest to make distributions from his IRA in the
aggregate amount of $331,500, as follows : Date Amoun t
Jan . 4, 1999 $70,00 0
Jan . 4, 1999 20,00 0
Feb . 1, 1999 15,00 0
Apr . 26, 1999 30,000
-11May 13, 1999 30,00 0
May 31, 1999 15,00 0
July 19, 1999 20,00 0
July 19, 1999 50,00 0
Sept . …
IRCCourt RulingsApr 2, 2024
… cannot limit the plain meaning of
the text.” See Bhd. of R.R. Trainmen v. Balt . & Ohio R.R. Co. , 331 U.S.
17
519, 528– 29 (1947); see also § 7806(b) (providing that no “descriptive
matter relating to the content of this title [shall] be given any legal
effect”). They are, however, “‘tools available for the resolutio…
IRCCourt RulingsJul 2, 2003
…erved. Taylor v. Commissioner
, 67 T.C. 1071, 1077 (1977);
Sperapani v. Commissioner
, 42 T.C. 308, 331 (1964). On the other
hand, if the requirements are procedural or directory in that
they do not go to the essence of the thing to be done, but rather
- 8 -
are given with a view to the orderly conduct of business, the…
IRCCourt RulingsJan 28, 2002
… was retired and lived in Mississippi when he
filed the petition.
In 1998, petitioner received $217,331.44 in retirement
distributions and $920.09 in nonemployee compensation. In 1998,
Primerica Life Insurance Co. issued to petitioner three Forms
1099-MISC, Miscellaneous Income, which state that he received
$920.09 of …
IRCCourt RulingsMay 23, 1979related by meaning
ld require the inclusion of some amount, as a human capital investment, in determining the value of his personal services rendered to the corporation. For a variety of reasons, we decline to adopt such a rule. It is well settled that the individual identities of different taxable entities must be respected. Burnet v. C…
64 T.C. 1011 — Catawba Industrial Rubber Co. v. Commissioner IRCCourt RulingsSep 9, 1975
…meet the requirements of sec. 401(a)(3), (4), (5), and (6) in sec. 401(b). See Aero Rental, 64 T.C. 331 (1975). Respondent agrees that this fact alone would not negative the existence of a qualified trust in petitioner’s fiscal year 1972, if a contribution was made to an existing trust within the grace period provided …
IRCCourt RulingsJul 24, 1995
…bserved. Taylor v. Commissioner, 67 T.C. 1071, 1077 (1977); Sperapani v. Commissioner, 42 T.C. 308, 331 (1964). On the other hand, if the requirements are procedural or directory in that they do not go to the essence of the thing to be done, but rather are given with a view to the orderly conduct of business, they may …
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
B. 2026-01 143
2026-4 2026-01 I.R.B. 2026-01 160
2026-5 2026-01 I.R.B. 2026-01 258
2026-6 2026-02 I.R.B. 2026-02 314
2026-7 2026-02 I.R.B. 2026-02 316 2026-8 2026-04 I.R.B. 2026-04 380
2026-9 2026-04 I.R.B. 2026-04 393
2026-10 2026-04 I.R.B. 2026-04 394
2026-12 2026-07 I.R.B. 2026-07 535
2026-13 2026-09 I.R.B. 2026-09 …