145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
Notice 2026-34 — 2026 Cumulative List of Changes in Plan Qualification Requirements for Defined Benefit Qualified Pre-approved Plans IRCNoticesJun 1, 2026
…dment is provided in section 7 of Rev. Proc. 2023-37. However, Q&A J-1 of Notice 2024-2, 2024-2 IRB 316, provides additional guidance with respect to the deadlines for interim or discretionary amendments adopted to reflect applicable provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L.…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026
…dment is provided in section 7 of Rev. Proc. 2023-37. However, Q&A J-1 of Notice 2024-2, 2024-2 IRB 316, provides additional guidance with respect to the deadlines for interim or discretionary amendments adopted to reflect applicable provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L.…
IRCCourt RulingsApr 11, 2012★ strong match
…wing relevant amounts on its Federal
income tax returns:
2001 2002 2003
Total incomel $2,527,967 $2,316,241 $2,137,828
Less: Total deductions 2,569,771 2,274,031 2,138,283
Taxable income (41,804) (223) (455)
- 7 -
1Gross receipts less cost of goods sold.
2Amount includes deductions for net operatiing loss from 2001.
In…
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
addition, the notice invites comments from the public regarding all aspects of these provisions.
ADMINISTRATIVE
Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…
88 FR 76032 — Proposed Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
tionary authority or control with respect to IRAs could continue to rely on PTE 86-128, as long as they comply with all of the exemption's conditions. The Department is also proposing certain technical changes to the exemption, including deleting subsection IV(b)(1), and redesignating remaining sections as needed. The …
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008
…dends at
all, because a dividend is defined as a payment oy a corporation
to its shareholders. Sec. 316(a). The SIP is the owner of the
preferred stock; it cannot be the payor of dividends under
section 316. These distribution payments represent only the
distribution of the proceeds of a dividend paid ioy petitioner to…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026
… agency of the Treasury Department, which includes the IRS.
9 Q&A J-1 of Notice 2024-02, 2024-2 IRB 316, sets forth the general deadlines for a plan sponsor to amend its eligible retirement plan for required and discretionary amendments to reflect the SECURE 2.0 Act. This notice extends the deadline for a plan sponsor …
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJul 13, 1995
…tain the effect of a distribution of property by the corporation to its shareholders. Secs. 301(c), 316(a). A distribution is treated as a dividend to the extent of the corporation’s earnings and profits. Sec. 316(a). If a distribution is made in excess of current and accumulated earnings and profits, the excess is tre…
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…
85 FR 2303 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Jan 15, 2020
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, rate set 316 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set
For plans with a valuation date
Immediate annuity rate
(percent)
Deferred annu…
IRCCourt RulingsSep 30, 1991related by meaning
o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409… IRCTreasury DecisionsJan 18, 2005related by meaning
INCOME TAX
Rev. Rul. 2005-3 Rev. Rul. 2005-3
Section 901(j)(5) Presidential waiver; Libya. Pursuant to a section 901(j)(5) Presidential waiver, section 901(j)(1) of the Code ceased to apply to Libya effective December 10, 2004. Section 911(d)(8) is not applicable to Libya after September 20, 2004, and Iraq after July 2…
IRCProposed Rules (FR)Proposed May 13, 2026
…
Review & Update Notice (Subsequent Years)
0
152,127
0.35
Average Mail Disclosure (20 participants)
316,513
316,513
0.73
Per Plan First Year Costs
2.13
Per Plan Subsequent Year Costs
1.08
* The cost per entity reflects the total costs of the regulation averaged to account for the 434,477 small, non-Federal group health…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsMar 20, 1997
…
whatever source derived including, inter alia, interest and
dividends. Sec. 61(a)(4), (7). Section 316(a) defines dividends
as any distribution of property made by a corporation to its
shareholders to the extent of earnings and profits. Dividends
may be formally declared, or they may be constructive. Noble v.
Commissi…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
IRCCourt RulingsSep 25, 1996
…MIT 82 accordingly reported partnership taxable income of
$840,069 for 1987. This consisted of $637,316, one-fourth of the
- 45 -
$2,549,264 deferred income that it was allocating over 4 years,
plus $231,253 in accrued interest payable from MPC, less
$28,500--a management fee expense to BBPA.
On its partnership return …