T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated … IRCTreasury DecisionsDec 6, 2021
…der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
IRCCourt RulingsAug 30, 1999related by meaning
eives any amount from a qualified retirement
plan (as defined in section 4974(c)), the taxpayer's
tax under this chapter for the taxable year in which such amount is received shall be increased by an amount
equal to 10 percent of the portion of such amount which
is includible in gross income.
A "qualified retirement pl…
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
hich is owned by U.S. Corp, in a transaction qualifying under section 351. U.S. Corp and DS are members of the same consolidated group.
(ii)
Analysis. Pursuant to § 1.987-2(c)(2)(i) and (ii), as a result of the deemed exchange of the assets and liabilities of Business A for DS stock in a section 351 transaction, Busine…
86 FR 66662 — Prescription Drug and Health Care Spending IRCFinal Rules (FR)Nov 23, 2021
…der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…ured group market, where prescription drugs benefits are bundled rather than separately carved out.[351]
PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable) IRCPrivate Letter RulingsApr 23, 1999
…3.01(22) of Rev. Proc. 98-3, 1998-1 I.R.B. 102-3, the Service will not rule
on the application of § 351 of the Code to an exchange of stock in the formation of a holding
company. However, the Service has the discretion to rule on significant subissues that must be
resolved to determine whether the transaction qualifies…
IRCCourt RulingsJun 17, 1997
…Benefits
Trust" (E.I.N. 86-6184818):
10
1990
1991
1992
1993
1994
Interest income $232,158 $372,992 $351,722 $106,927 $92,464
Other income: forfeitures --- 9,453 --- --- ---
Other income: refund trustee fees --- --- --- --- 4,012
Tax exempt income 55,467 34,812 295,340 118,797 14,498
Total income 232,158 382,445 351,722…
IRCCourt RulingsJul 5, 1983related by meaning
the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
IRCCourt RulingsApr 24, 2017
…S-Corp. stock, as was necessary to qualify for nonrecognition of income under
- 19 - [*19] sections 351(a) and 368(c). Respondent urges that petitioners are
improperly "trying to have it both ways."
We are unpersuaded by this argument. Respondent does not contend that
the section 351 exchange was invalid and has not so…
IRCRegulationsDec 23, 2021
…der section 505(c) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 355(c)), or under section 351 of the PHS Act (42 U.S.C. 262), and that is generally marketed under a proprietary, trademark-protected name. The term “brand prescription drug” includes a drug with Emergency Use Authorization issued pursuant to sec…
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 RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
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 RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsMay 25, 2005related by meaning
ibution was not from an IRA, it would not qualify for the
exception for higher education expenses, even if it were used for
higher education expenses. Petitioners stated in their petition that the distribution
was from a section 401(k) account, a fact which petitioners have
not denied. Petitioners did not respond to th…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006
…elling shareholders includes an installment obligation of the purchasing entity.
(33) Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; and Stock for Stock of Same …
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…elling shareholders includes an installment obligation of the purchasing entity.
(31) Sections 332, 351, 368(a)(1)(A), (B), (C), (E) and (F), and 1036.—Complete Liquidations of Subsidiaries; Transfer to Corporation Controlled by Transferor; Definitions Relating to Corporate Reorganizations; and Stock for Stock of Same …
IRCCourt RulingsApr 16, 2020
…d a $17,070 insurance expense deduction on their 2014
Schedule C1. On brief respondent concedes $12,351 of that amount but contends
that petitioners failed to substantiate the remaining $4,719.
- 38 -
[*38] The record does not establish that BJW had insurance expenses in excess of
the amount respondent has conceded. On…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…