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57 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …ffiliated corporations to file consolidated returns”. B. Forman Co. v. Commissioner, 453 F.2d 1144, 1150 (2d Cir. 1972), aff’g in part , rev’g in part 54 T.C. 912 (1970). These statements are incorrect. The history of the Revenue Act of 1928 began with a bill that was introduced in the House and then referred to the Ho…
  2. 67 T.C. 131 — Babst Services, Inc. v. Commissioner
    IRCCourt RulingsNov 4, 1976
    …d at 393-394; Cornell-Young Co. v. United States, 469 F.2d at 1324; George Loevsky, 55 T.C. at 1149-1150.
  3. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    years beginning after the date of enactment of the Act); id. § 311(b)(2), 136 Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received). “This is the highly reticul…
  4. 75 FR 42605 — Increase in Tax Rates on Tobacco Products and Cigarette Papers and Tubes; Floor Stocks Tax on Certain Tobacco Products, Cigarette Papers, and Cigarette Tubes; …
    IRCFinal Rules (FR)Jul 22, 2010related by meaning
    Document Headings Document headings vary by document type but may contain the following: the agency or agencies that issued and signed a document the number of the CFR title and the number of each part the document amends, proposes to amend, or is directly related to the agency docket number / agency internal file numb…
  5. 72 T.C. 377 — La Mastro v. Commissioner
    IRCCourt RulingsMay 23, 1979
    …ories, Inc. v. Commissioner, 34 T.C. 549 (1960); Chatsworth Stations, Inc. v. Commissioner, 29 T.C. 1150 (1958), affd. and revd. on other issues 282 F.2d 132 (2d Cir. 1960).
  6. 82 FR 47656 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act; Proposed Rulemaking
    IRCProposed Rules (FR)Proposed Oct 13, 2017related by meaning
    CTION: Notice of proposed rulemaking by cross-reference to temporary regulations. ( printed page 47657) SUMMARY: In this issue of the Federal Register , the Department of Treasury and the IRS are issuing two sets of temporary regulations related to section 9815 of the Internal Revenue Code. The first set of temporary r…
  7. 67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner
    IRCCourt RulingsDec 16, 1976
    …, 631-632 (1974), affd. per curiam 518 F.2d 554 (8th Cir. 1975); George Loevsky, 55 T.C. 1144, 1149-1150 (1971), affd. per curiam 471 F.2d 1178 (3d Cir. 1973), cert. denied 412 U.S. 919 (1973); Ed & Jim Fleitz, Inc., 50 T.C. 384, 390 (1968); John Duguid & Sons, Inc. v. United States, 278 F.Supp. 101, 105 (N.D. N.Y. 196…
  8. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    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…
  9. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979★ strong match
    …e 182(c) and (d), and the Note thereto, Tax Court Rules of Practice and Procedure, 60 T.C.1057,1149-1150 (1973). FINDINGS OF FACT Some of the facts have been stipulated and those facts are so found. The stipulation of facts, supplemental stipulation of facts, and all attached exhibits are incorporated herein by this re…
  10. 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 …
  11. T.C. Memo. 2007-90 — Roger F. & Mary A. Duronio v. Commissioner
    IRCCourt RulingsApr 17, 2007related by meaning
    iable for the $1,990 10-percent additional tax on the $19,900 early IRA distribution Mary received. To reflect the foregoing, Decision will be entered under Rule 155 .
  12. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    motion for costs was filed out of time and should be "dismissed" for that reason. We reject respondent's contention and do not consider it further. 12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is generally applicable to proceedings commenced after …
  13. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  14. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  15. 80 FR 72006 — Savings Arrangements Established by States for Non-Governmental Employees
    ERISAProposed Rules (FR)Proposed Nov 18, 2015
    …s.” Back to Citation 4.  Illinois Secure Choice Savings Program Act, 2014 Ill. Legis. Serv. P.A. 98-1150 (S.B. 2758) (West); California Secure Choice Retirement Savings Act, 2012 Cal. Legis. Serv. Ch. 734 (S.B. 1234) (West); Oregon 2015 Session Laws, Ch. 557 (H.B. 2960) (June 2015). Back to Citation 5.
  16. 80 FR 71936 — Interpretive Bulletin Relating to State Savings Programs That Sponsor or Facilitate Plans Covered by the Employee Retirement Income Security Act of 1974
    ERISAFinal Rules (FR)Nov 18, 2015
    …(H.B. 2960) (June 2015); Illinois Secure Choice Savings Program Act, 2014 Ill. Legis. Serv. P.A. 98-1150 (S.B. 2758) (West); California Secure Choice Retirement Savings Act, 2012 Cal. Legis. Serv. Ch. 734 (S.B. 1234) (West). These IRA-based initiatives generally require specified employers to deduct amounts from their …
  17. PLR 201739010 — Church Plan
    IRCPrivate Letter RulingsSep 29, 2017related by meaning
    Internal Revenue Service Department of the Treasury Wa shington, DC 20224 Number: 201739010 Release Date: 9/29/2017 Index Number: 414.08-00 ------------------------------------------------------------ ----------------------------- ---------------------------- ----------------------------------- ------------------------…
  18. T.C. Summary Opinion 2004-29 — Howard T. Owens, Jr. & Ann E. Owens v. Commissioner
    IRCCourt RulingsMar 15, 2004related by meaning
    t 22, 2001, respondent issued to petitioners a notice of deficiency determining that they were liable for this additional tax in the amount of $2,000. Discussion I. General Rules In general, section 408 governs the treatment of IRAs. Specifically, section 408(d) provides that distributions from an IRA are taxable in th…
  19. 81 T.C. 652; 81 T.C. No. 38 — Doty v. Commissioner
    IRCCourt RulingsSep 28, 1983
    …ble to her. Johnson v. United States, 135 F.2d 125 (9th Cir. 1943); Hubner v. Commissioner, 28 T.C. 1150 (1957). Indeed, there is no dispute between the parties with respect to this point. The question, simply stated, is whether the income received by petitioner constituted earned income under section 1348.
  20. Ann. 2007-47 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsMay 14, 2007
    …oor New York, NY 10038 2/11/1992 210. SBM Financial Services, Inc. 8400 Normandale Lake Blvd. Suite 1150 Minneapolis, MN 55437 5/13/1995 211. Scott & Stringfellow, Inc. (FKA Craige, Inc.) 823 E. Main Street Richmond, VA 23219 5/5/1999 212. Scottsdale Securities, Inc. 12855 Flushing Meadow St. Louis, MO 63131 10/9/1996 …