89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit IRCFinal Rules (FR)Dec 11, 2024
…tion 1.861-14T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f).
* * * * *
Section 1.985-0 also issued under 26 U.S.C. 985.
Section 1.985-1 also issued under 26 U.S.C. 985.
Section 1.985-2 also issued under 26 U.S.C. 985.
Section 1.985-3 also issued under 26 U.S.C. 985.
Section 1.985-4 also issued under …
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
…tion 1.861-14T also issued under 26 U.S.C. 863(a), 864(e), 865(i), and 7701(f).
* * * * *
Section 1.985-0 also issued under 26 U.S.C. 985.
Section 1.985-1 also issued under 26 U.S.C. 985.
Section 1.985-2 also issued under 26 U.S.C. 985.
Section 1.985-3 also issued under 26 U.S.C. 985.
Section 1.985-4 also issued under …
IRCCourt RulingsNov 12, 1981related by meaning
n was for personal purposes; the petitioners have utterly failed to produce such evidence, and therefore, we sustain the Commissioner’s determination. The final issue for decision is whether any part of the underpayment of tax for 1975 was due to negligence or intentional disregard of rules and regulations within the m…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
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…
IRCCourt RulingsApr 14, 2005
…l. & Executive Leasing, Inc.
v. Commissioner
, supra
at 232; Simpson v. Commissioner
, supra
at
984-985; see also sec. 31.3401(c)-1(b), Employment Tax Regs. The
factor generally considered fundamental for resolving the
- 17 -
question of whether an individual is an employee is the degree of
control exercised by the per…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
- 18 -
4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
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…
80 FR 21960 — Proposed Best Interest Contract Exemption ERISAProposed Rules (FR)Proposed Apr 20, 2015
… other for-profit.
Estimated Number of Respondents:
2,800.
Estimated Number of Annual Responses:
85,985,156 in the first year and 66,394,985 in subsequent years.
Frequency of Response:
Initially, Annually, and When engaging in exempted transaction.
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsJul 8, 1980related by meaning
alty in question has its roots in subtitle C of the Internal Revenue Code (Employment Taxes), a subtitle which falls outside the Court’s jurisdiction. Petitioners failed to file a timely objection to respondent’s motion, and on February 22, 1980, an order granting the motion was entered. Subsequently, on March 21, 1980…
IRCCourt RulingsAug 28, 1996related by meaning
…r the 1991
excise tax deficiency. Sec. 6213; Stamm Intl. Corp. v.
Commissioner
, 84 T.C. 248, 252 (1985). Questions of jurisdiction
must be decided whenever it appears that we may not have
jurisdiction. Wheeler's Peachtree Pharmacy, Inc. v.
Commissioner
, 35 T.C. 177, 179 (1960).
Section 6212, in pertinent part, provid…
IRCCourt RulingsJul 13, 1995related by meaning
…tifiably relied on a handbook published by respondent for guidance), affd. 755 F.2d 790 (11th Cir. 1985).
We have considered petitioner’s remaining arguments and find them to be without merit. Accordingly, we find that respondent did not abuse her discretion in applying the regulation retroactively.
Conclusion
In concl…
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCRevenue ProceduresSuperseded
…VERVIEW AND DEFINITIONS
SECTION 1. PURPOSE
.01 Section 21.02 of Rev. Proc. 2013-22 , 2013-18 I.R.B. 985, as modified by
Rev. Proc. 2014-28, 2014-16 I.R.B. 944, and Rev. Proc. 2015-22, 2015-22 I.R.B. 754,
and clarified by Rev. Proc. 2017-18, 2017-5 I.R.B. 743,
1
establishes a remedial
amendment period that permits an El…