IRCCourt RulingsDec 20, 2001
tock purchase agreement),
pursuant to which Mr. Whitehead purchased on that date for
$178,000 all 35,280 shares of Mr. Stanford’s Burien Nissan stock. That agreement provided that Mr. Whitehead was to pay the purchase price of $178,000 by delivering to Mr. Stanford a nonnegotiable promissory note.
In the September 13, …
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…lternative investments would add multiple series.[122] These plans would, in aggregate, have about $178 billion and 4.5 million participants flowing each year into target date funds with alternative investments. While the Department estimated these figures using the detailed data available for large 401(k) plans, it ex…
IRCCourt RulingsFeb 18, 1997related by meaning
ioner's retirement distribution's
being taxed twice. We think petitioners' contention is
meritorious. Here we take note of the long-standing principle that double taxation is to be avoided unless expressly intended
by Congress. E.g., Maass v. Higgins
, 312 U.S. 443, 449 (1941);
United States v. Supplee-Biddle Hardware …
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
… had engaged in spread pricing which cost the State program nearly $225 million in excess payments.[178]
Ohio brought a lawsuit against Centene, who ultimately agreed to pay $88.3 million to the State [179]
and also switched to a pass-through pricing contract, which increased payments to pharmacists by 5.74 percent, th…
IRCCourt RulingsFeb 28, 2024related by meaning
argument that the statute of limitations should be treated as
a substantive limit on their case rather than as a procedural limit on the
reme dy) .
40 The Supreme Court observed in Landgraf that “the great majority of [its] decisions relying upon the antiretroactivity presumption have
involved intervening statutes burd…
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
…Review of determination letters
177
SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER?
178
.01 Scope of this section
178
.02 Scope of determination letters
178
.03 Design-based safe harbor
178
.04 Governmental plans under § 414(d)
178
.05 Church plans under § 414(e)
178
.06 Tax treatment of certain contrib…
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
…t
177
.14 Where to file requests
177
.15 Submission of related plans
177
.16 Withdrawal of requests
178
.17 Right to status conference
178
.18 How to request status conference
178
.19 Correct format required
178
SECTION 11.WHAT IS THE PROCESS FOR REQUESTING DETERMINATION LETTERS FOR NDIVIDUALLY DESIGNED PLANS?
178
.01 …
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 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 RulingsFeb 9, 2023★ strong match
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCProposed Rules (FR)Proposed May 13, 2026
…l Annual Burden Cost:
$381,544.
V. Regulatory Flexibility Act
The Regulatory Flexibility Act (RFA) [178]
IRCCourt RulingsOct 11, 1957★ strong match
s that its enforcement would amount to a deprivation of property without due process of law as required under the Fifth Amendment to the Constitution. We have carefully considered the decision of the Seventh Circuit in the Kohl case, and its application as a precedent in the problem which confronts us. With all due res…
IRCCourt RulingsJul 5, 1983related by meaning
so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019
…ividually designed plans
177
.03 Forms
177
.04 Application must include copy of plan and amendments
178 .05 Restatements required
178
.06 Section 414(x) combined plans
178
SECTION 12. WHEN MAY AN ADOPTER OF A MASTER AND PROTOTYPE OR VOLUME SUBMITTER PLAN SUBMIT A DETERMINATION LETTER APPLICATION?
178
.01 Eligibility to…
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023
…den hours
Equivalent burden cost
Burden hours
Equivalent burden cost
Independent Producer
20,000
$3,178,800
20,000
$3,178,800
Total
20,000
3,178,800
20,000
3,178,800
1.4. Overall Summary
These paperwork burden estimates are summarized as follows:
Type of Review:
Revision of an Existing Collection.
Agency:
Employee Bene…
Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023
…FOR REQUESTING LETTER RULINGS AND DETERMINATION LETTERS FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS?
178
.01 In general
178
.02 Certain information required in requests for letter rulings or determination letters, as applicable
178
.03 Additional information required in certain circumstances
188
.04 Address to send the …