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 RulingsSep 13, 1990related by meaning
y [section 403(a) of ERTA],
then the amendment made by [section 403(a) of ERTA] shall not apply to the estate of such decedent.
[1981-2 C.B. 326-327.] *295 Respondent asserts that all the conditions contained in section 403(e)(3) have been met. Therefore, *99 he maintains, petitioner is not entitled to an unlimited mar…
IRCCourt RulingsFeb 22, 1989★ strong match
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
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 …
73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner IRCCourt RulingsJan 31, 1980related by meaning
1974, Pub. L. 93-406,88 Stat. 829, applicable generally to taxable years beginning after Dec. 31, 1975.
Sec. 1.401-6 Termination of a qualified plan. (a) General rules. (1) In order for a pension, profit-sharing, or stock bonus trust to satisfy the requirements of section 401, the plan of which such trust forms a part…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent.
Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
IRCCourt RulingsFeb 9, 2023related by meaning
owing
differences:
I --between the amounts of royalties and other
expenses referred to in article 74 of the
mentioned Law, credited or paid during the base-year, and the minimum percentages
established for the respective deduction,
according to (b) and (d);
II--between the quotas for the purpose of
forming depreciation…
IRCPrivate Letter RulingsJan 10, 2003
tion 451 and the regulations thereunder. E represents that its
board intends to adopt a corporate resolution that freezes and bars future deferrals to its five existing NQDC plans described above upon E’s receiving a favorable
determination letter establishing its status as a tax-exempt organization described in
sectio…
T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner IRCCourt RulingsApr 27, 1998
….
Generally, income is includable in a taxpayer's gross income
in the year of receipt under section 451(a).
2
However, the Congress has provided more specialized rules in the area of
employee plans, and where applicable, these rules govern instead
of the more general accounting rules identified under section
451(a). Se…
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…
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
…irements of Rev. Proc. 92-65, 1992-2 C.B. 428, and Rev. Proc. 71-19, 1971-1 C.B. 698. (72) Sections 451 and 457.—General Rule for Taxable Year of Inclusion; Deferred Compensation Plans of State and Local Governments and Tax-Exempt Organizations.—The tax consequences to unidentified independent contractors in nonqualifi…
IRCPrivate Letter RulingsJul 30, 1999
e transferor's creditors, for example, in a trust or escrow account.
Section 451(a) of the Code and section 1.451-1(a) of the regulations provide that an item of gross income is includible in gross income for the taxable year in which
actually or constructively received by a taxpayer using the cash receipts and
disburs…
IRCPrivate Letter RulingsNov 13, 2015
… such contribution is substantially vested, as defined in the regulations under section 83.
Section
451 (a) of the Code and section 1.451-1 (a) of the regulations provide that an
item
of gross income is includible in gross income for the taxable year in which actually
or constructively received by a taxpayer using the …
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 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
PLR 200302032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 10, 2003
…l.
This language is substantially similar to language contained in section 83 of the Code.]
Section 451(a) of the Code and section 1.451-1(a) of the regulations provide that
an item of gross income is includible in gross income for the taxable year in which
actually or constructively received by a taxpayer using the ca…
IRCCourt RulingsDec 29, 2005related by meaning
ic employees, (2) the
plan would pay her a taxable annuity after she reaches age 60,
(3) the plan has no survivor benefits, and (4) she would lose all benefits under the plan if she stopped contributing to it.
. The record includes a summary of a tax convention signed by
representatives of France and the United States …
PLR 200301032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 3, 2003
…al.
This language is substantially similar to language contained in section 83 of the Code.
Section 451(a) of the Code and section 1.451-1(a) of the regulations provide that
an item of gross income is includible in gross income for the taxable year in which
actually or constructively received by a taxpayer using the ca…
PLR 200202027 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 11, 2002
…y, the rules of section 457 do not apply to the PTO Plan
(including the proposed revision).
Section 451(a) of the Code and section 1.451-1(a) of the regulations provide that
an item of gross income is includible in gross income for the taxable year in which
actually or constructively received by a taxpayer using the ca…
IRCPrivate Letter RulingsFeb 5, 1999
…
substantially vested (as defined in section 1.83-3(b)) at the
time such premiums are paid.
Section 451(a) of the Code and section 1.451-1(a) of the regulations provide that an item of gross income is includible in
gross income for the taxable year in which actually or
constructively received by a taxpayer using the ca…