IRCCourt RulingsDec 31, 1957
…0 (e) as having “commenced business” only if they would likewise so qualify as described in section 445. Section 445 .expressly requires for its application the use of the principle of section 503. We fail to see, therefore, how a corporation can have the benefits of not having commenced business before July 1, 1945, u…
IRCCourt RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
IRCCourt RulingsSep 18, 1996related by meaning
begin with section 4973.
Section 4973
Section 4973(a) imposes a 6-percent excise tax on excess
contributions to an IRA. As relevant herein, an "excess contribution" is the amount in excess of the amount allowable as
a deduction under section 219 (computed without regard to section
- 27 -
219(g)), exclusive of amounts p…
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…
PBGCProposed Rules (FR)Proposed Aug 18, 2023
…riting to Disclosure Division, Office of the General Counsel, Pension Benefit Guaranty Corporation, 445 12th Street SW, Washington, DC 20024-2101, or calling 202-326-4040 during normal business hours. If you are deaf or hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay s…
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
HHS proposes to make conforming amendments to 45 CFR 150.445(g), which pertains to admissibility of evidence of acts other than those at issue in the instant case, to add references to the proposed 45 CFR 150.513 (which describes factors and mitigating and aggravating circumstances considered in determination of the am…
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 RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…vision ( disclosure@pbgc.gov), Office of the General Counsel, Pension Benefit Guaranty Corporation, 445 12th Street SW, Washington, DC 20024-2101, or calling 202-326-4040 during normal business hours. If you are deaf or hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay s…
91 FR 36100 — Technical Amendments: Special Financial Assistance PBGCProposed Rules (FR)Proposed Jun 16, 2026
…vision (
disclosure@pbgc.gov), Office of the General Counsel, Pension Benefit Guaranty Corporation, 445 12th Street SW, Washington, DC 20024-2101 or calling 202-326-4040 during normal business hours. If you are deaf or hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay se…
90 FR 6894 — Miscellaneous Corrections, Clarifications, and Improvements PBGCProposed Rules (FR)Proposed Jan 21, 2025
…vision ( disclosure@pbgc.gov), Office of the General Counsel, Pension Benefit Guaranty Corporation, 445 12th Street SW, Washington, DC 20024-2101, or calling 202-326-4040 during normal business hours. If you are deaf or hard of hearing, or have a speech disability, please dial 7-1-1 to access telecommunications relay s…
91 FR 45739 — Penalties for Failure To Provide Certain Notices or Other Material Information PBGCProposed Rules (FR)Proposed Jul 21, 2026
…ative and Regulatory Division, Office of the General Counsel, Pension Benefit Guaranty Corporation, 445 12th Street SW, Washington, DC 20024-2101.
Commenters are strongly encouraged to submit comments electronically. Commenters who submit comments on paper by mail should allow sufficient time for mailed comments to be …
IRCCourt RulingsMar 7, 2019
…
• "You Must Apply Rule of Law on a Daily Basis! After all, you are not working for the IRS, or the 445 legal thieves in Washington, DC.
They will legally take your money. They will then redistribute it to
those individuals who will not work as you have worked. Will you
use RULE OF LAW and stop the 445 legal thieves?"7…
PBGCFinal Rules (FR)Sep 22, 2022
…moving “1200 K Street NW, Washington, DC 20005-4026,” wherever it appears, and adding in its place “445 12th Street SW, Washington, DC 20024-2101,”.
Appendix A to Part 4233 [Amended]
5. Amend appendix A to part 4233 by removing “1200 K Street NW, Washington, DC 20005-4026” wherever it appears, and adding in its place “…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
IRCCourt RulingsJul 14, 2005related by meaning
er for calendar year
1993 except that the reference to "20% reduction" was changed to
"50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA
1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this
connection, prior to its amendment by OBRA …
IRCCourt RulingsSep 26, 2001related by meaning
effect, rewrite
the statute to achieve what seems to be a more equitable result.
See Eanes v. Commissioner
, supra
at 171. “Whether and to what
- 6 - extent deductions shall be allowed depends upon legislative
grace; and only as there is clear provision therefor can any
particular deduction be allowed.” New Colonial Ic…
75 FR 70114 — Amendment to the Interim Final Rules for Group Health Plans and Health Insurance Coverage Relating to Status as a Grandfathered Health Plan Under the Patient P… IRCFinal Rules (FR)Nov 17, 2010
… and Insurance Oversight, Department of Health and Human Services, Attention: OCIIO-9991-IFC2, Room 445-G, Hubert H. Humphrey Building, 200 Independence Avenue, SW., Washington, DC 20201.
Please allow sufficient time for mailed comments to be received before the close of the comment period.
By express or overnight mail…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…