IRCCourt RulingsJun 18, 1999★ strong match
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
IRCCourt RulingsDec 29, 2005★ strong match
ments, as
in effect in 2001.
Article 18(2)(a) of the 1994 U.S./French Tax Convention
provides that contributions to a French retirement plan generally are treated in computing U.S. tax as though they were paid to a
pension or other retirement arrangement established and
recognized for tax purposes in the United States …
IRCCourt RulingsJan 17, 2024related by meaning
3 in
p articular s erve what is principally a regulatory functio n —persuading
public charities, private foundations, employee trusts, and other tax - fa vored plan s to comply with the requirement s Congress has ordaine d
for continued tax-exempt status.
Section 4973 imposes a 6% exaction on the amount of an excess
co…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
… two surveys' findings as a basis, the Department assumes the meeting frequency factors in Table 6.[199]
IRCCourt RulingsAug 30, 1999related by meaning
tions in his gross income for 1995.
The only exception to section 408(d)(1) that might apply in
the present case is section 408(d)(6), which provides: (6) Transfer of account incident to divorce.--The
transfer of an individual's interest in an individual
retirement account or an individual retirement annuity
to his spo…
IRCCourt RulingsJan 27, 1998related by meaning
) and (b) of section 4975.
Section 4975 was added to the Internal Revenue Code by title
II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions.
The policy behind the enactment of section 4975 was to tax
disqualified persons who engage in self-deal…
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 …
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…than doubled from 2011 to 2013, indicating a substantial increase after the final rule took effect.[199]
IRCCourt RulingsSep 25, 2000related by meaning
provisions” including
section 4975. The tax provisions, contained in the Internal
- 6 -
Revenue Code, provide the statutory framework for the tax laws governing employee benefit plans and generally are administered
by the Department of the Treasury. See Rutland v. Commissioner
,
89 T.C. 1137, 1143 n.4 (1987).
There are…
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
…ed guidance
198
.05 Issues in prior return
198
.06 Generally not to business associations or groups
199
.07 Generally not to foreign governments
199
.08 Generally not on federal tax consequences of proposed legislation
199
SECTION 25. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HAVE THE DISCRETI…
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
…1-1(a)(1) and (2) as to who is the owner of a qualified film or television production. (42) Section 199.—Income Attributable to Domestic Production Activities.—The determination under § 1.199-3(f)(1) as to who is the taxpayer that has the benefits and burdens of ownership under Federal income tax principles of any qual…
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
…e a copy of plan and amendments
198
.04 Restatements required
198
.05 Section 414(x) combined plans
199
SECTION 12. WHEN MAY AN ADOPTER OF A PRE-APPROVED PLAN (STANDARDIZED OR NONSTANDARDIZED) SUBMIT A DETERMINATION LETTER APPLICATION?
199
.01 Eligibility to apply for a determination letter for a Cycle 3 qualified pre-…
Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t… IRCRevenue ProceduresSuperseded Jan 4, 2021
…03 Determination letter applications on Form 5300
196
.04 Scope of review
198
.05 Submission period
199
.06 Reliance equivalent to determination letter
199
SECTION 13. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR FORM 5307?
199
.01 Scope
199
.02 Form 5307 filing procedures
199
.03 Additional information with…
IRCCourt RulingsDec 16, 1998related by meaning
rty within the
10-year period ending on the date of the transfer.
(4) Amount involved.--The term "amount
involved" means, with respect to a prohibited transaction, the greater of the amount of money and
the fair market value of the other property given or
the amount of money and the fair market value of the
other prope…
IRCCourt RulingsFeb 25, 2016
…er Strategies is entitled to business expense deductions for meals
and entertainment expenses of $2,199 and $4,739 for 2004 and 2005, respectively,
and travel expenses of $53,707 for 2005;
(4) whether petitioner is liable for additions to tax under section 6651(a)(1)
for failure to file Forms 5329, Additional Taxes on …
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
…f subsequent publication of revenue ruling, etc.
198
.04 Effect of subsequent amendment by employer
199
.05 Revocation or modification of a determination letter
199
.06 Determination letter revoked or modified based on material change in facts applied retroactively
199
.07 Not otherwise generally revoked or modified re…
IRCCourt RulingsJun 1, 1987related by meaning
significance save that the words are strung together with syntactical correctness. * * * [Hand, “Thomas Walter Swan,” 57 Yale L. J. 167, 169 (1947).] Section 4975, as added to the Internal Revenue Code by title II of ERISA, Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, imposes two levels of excise tax on a prohibited …
75 FR 19542 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Apr 15, 2010
…)
On or after Before
i1
i2
i3
n1
n2
* * * * * * *
199
5-1-10
6-1-10
3.00
4.00
4.00
4.00
7
8
3. In appendix C to part 4022, Rate Set 199, as set forth below, is added to the table.
APPENDIX C TO PART 4022—LUMP SUM INTEREST RATES FOR PRIVATE-SECTOR PAYMENTS
* * * * *
( pr…
IRCCourt RulingsFeb 22, 1989related by meaning
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…
IRCCourt RulingsNov 30, 2006★ strong match
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…