IRCCourt RulingsFeb 9, 2023related by meaning
E llipsis in original opinion .)
132
This same text quoted in First Security
Bank is found in the 1962 regulations, 26 C.F.R. sec. 1.482-1(b)(1) (1961 ed. 1965 Cum. Supp.), and in the 1968 regulations, 26 C.F.R. sec. 1.482-1(b)(1) (1969), but is slightly different from the 1953 regulations, 26
C.F.R. sec. 39.45-1(b)(1)…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…fy the plan's or issuer's current process, resulting in a one-time burden for each issuer or TPA of 192 hours with an estimated associated cost of $27,728. For all 1,580 issuers and TPAs, as shown in Table 12, the Departments estimate a total one-time burden of 303,360 hours with an estimated associated cost of $43,810…
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 RulingsAug 8, 2005
T.C. Memo. 2005-192
UNITED STATES TAX COURT
ARTHUR F. MILLARD, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3713-04. Filed August 8, 2005.
Arthur F. Millard, pro se.
Travis T. Vance III
, for respondent.
MEMORANDUM OPINION
WELLS, Judge
: Respondent determined a deficiency of $2,764
in petition…
IRCCourt RulingsJan 31, 2001
…ash.
By check dated December 21, 1995 (the check), Vanguard
Fiduciary Trust Co. (Vanguard) paid $23,192.18 to the order of
Meagan Elizabeth Stahl. The check states: “E-Systems, Inc.”,
“Disbursement Account”, and “Plan Number 091184". For 1995,
Vanguard issued a Form 1099R, “Distributions From Pensions,
Annuities, Retir…
37 T.C. 7 — Barbourville Brick Co. v. Commissioner IRCCourt RulingsOct 9, 1961related by meaning
ar 1954 under the provisions of section 404(a)(5), and section 1.404(a)-12, Income Tax Regs.
On brief, petitioner states the “Issue To Be Decided” as— Where the petitioner obligated itself to pay to the widow of its deceased President an amount equivalent to the monthly salary of the deceased President for a period of …
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…
IRCFinal Rules (FR)Aug 26, 2022
…burden-calculations-june-2019.pdf.) The composite wage rate is estimated in the following manner: ($192.37 × (
1/3
) + $109.03 × (
2/3
) = $136.81).
Back to Citation
85.
17,453 claims × 0.5 hours × $136.81 as the composite wage rate for a physician and medical billing specialist = $1,192,641.
Back to Citation
86.
The…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…nd that between 2001 and 2009,[191] alternative assets contributed positively to portfolio returns,[192]
but since 2010, alternative assets have had a negative effect on portfolio performance.[193]
Korteweg, Panageas, and Systla (2024) looked more specifically at how private equity investments have contributed to publi…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…n costs based on data reported by pharmacies to the Centers for Medicare & Medicaid Services (CMS).[192]
While PBMs offer lower cost-sharing on generics, PBMs can still steer patients toward affiliated pharmacies and give those pharmacies preferential reimbursement rates. This practice allows PBM-affiliated pharmacies …
38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner IRCCourt RulingsSep 21, 1962related by meaning
Senate Finance Committee with respect to the enactment of the Excess Profits Tax Act of 1950 make it clear that this interpretation is the proper one. Section 430 of the Internal Revenue Code is a part of chapter I of the 1939 Code and section 272(a) of the Internal Revenue Code of 1939 refers to the determination of a…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…e
employees, it has done so
clearly. For example, the funding period for purposes of
- 44 -
20
Sec. 192(b) limits contributions to a black lung benefit
trust as follows:
SEC. 192(b). Limitation.--The maximum amount of the
deduction allowed by subsection (a) for any taxpayer for
any taxable year shall not exceed the gre…
IRCCourt RulingsJul 24, 1991related by meaning
tever source derived, including (but not limited to) the following items: *******
(11) Pensions;
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020
…T ARE THE DETERMINATION LETTER FILING PROCEDURES FOR INDIVIDUALLY DESIGNED MULTIPLE EMPLOYER PLANS?
192
.01 Scope
192
.02 Applicant must request letter for plan in the name of the controlling member
192
.03 Where to file requests
192
.04 Addition of employers
192
SECTION 15. WHAT ARE THE PROCEDURES FOR FILING A REQUEST…
IRCCourt RulingsJul 18, 1968related by meaning
62 (or sec. 404) and under other provisions, such as interest tolvich is specifically allowable as a deduction under section 16$. [Emphasis supplied.] H. Rept. No. 749, 88th Cong., 1st Sess. p. 82 (1968). See also H. Rept. No. 749, p. A92 (1963).
In view of these statutory changes, McNutt-Boyce Co., supra, is no longer…
Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division… IRCRevenue ProceduresJan 2, 2018
…it comments
191
.04 Right to comment if DOL declines to comment
191
.05 Confidentiality of comments
192 .06 Availability of comments
192
.07 When comments are deemed made
192
SECTION 20. WHAT ARE THE GENERAL RULES FOR NOTICE TO INTERESTED PARTIES?
192
.01 Notice to interested parties
192
.02 Time when notice must be gi…
Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of … IRCRevenue ProceduresModified Dec 29, 2025
…tions under § 414(h)
191
.07 Other limits on scope of determination letter
191
.08 Leased employees
192
.09 Partial terminations
192
.10 Publication 794, Favorable Determination Letter
192
SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS?
192
.01 Scope
192
.02 Complete information required…
IRCCourt RulingsJul 3, 1974related by meaning
ilar to the enumerated plans and that it therefore should not be treated in accordance with section 404 (a) but rather in accordance with section 162. Although a literal interpretation of the first sentence of section 404(a) would appear to support the position of respondent, we are not confined to such a literal readi…
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017
…03 Determination letter based solely on administrative record
191
.04 Notice of final determination
192
.05 Issuance of the notice of final determination
192
SECTION 22. WHAT ARE THE STEPS FOR EXHAUSTING ADMINISTRATIVE REMEDIES?
192
.01 In general
192
.02 Steps for exhausting administrative remedies
192
.03 Applicant’s…
Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Dec 30, 2024
…Review of determination letters
191
SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER?
192 .01 Scope of this section
192
.02 Scope of determination letters
192
.03 Design-based safe harbor
192
.04 Governmental plans under § 414(d)
193
.05 Church plans under § 414(e)
193
.06 Tax treatment of certain contrib…