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90 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024★ strong match
    … Th at is because there may be “diminished reliance interests in matters of procedure . ” Landgraf, 511 U.S. at 275; see Bacon , 82 F.3d at 824 (“ Changes in procedural rules may often be applied in suits arising before their enactment without raising concerns about retroactivity .” ( quoting Landgraf, 511 U.S. at 275)…
  2. 85 FR 23172 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business
    IRCProposed Rules (FR)Proposed Apr 24, 2020
    …d in sections 401(a) and 501(c) generally are exempt from federal income taxation. However, section 511(a)(1) imposes a tax (computed as provided in section 11) on the unrelated business taxable income (UBTI) of organizations described in section 511(a)(2), which includes organizations described in sections 401(a) and …
  3. 71 T.C. 765 — Elliot Knitwear Profit Sharing Plan v. Commissioner
    IRCCourt RulingsFeb 12, 1979
    …nder sec. 514, I.R.C. 1954, 1 and that the income earned on those securities was taxable under sec. 511 to the extent of the debt-financing. Held, the securities are debt-financed property within the meaning of sec. 514(b), and the debt-financed portion of the income and gain from those securities is subject to tax und…
  4. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    individual employer contributors to determine their deduction limits in the tenebrous context of overlapping tax and plan years. Consequently, section 404(a)(6), by its reference to section 404(a)(1) through (3), has an impact on section 413(b)(7). Petitioner maintains that, if an individual employer's tax treatment of…
  5. 78 T.C. 812; 78 T.C. No. 57 — Service Bolt & Nut Co. Profit Sharing Trust v. Commissioner
    IRCCourt RulingsMay 20, 1982
    income within the meaning of section 511 as a result of holding limited partnership interests in various wholesale fastener distributing partnerships. Petitioners argue that a limited partnership interest is a passive investment that cannot, unlike a general partnership interest, produce unrelated business taxable inco…
  6. PLR 201440022 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsOct 3, 2014
    …n Number: Telephone Number: Taxpayer Identification Number: Uniform Issue List 419.00-00 419A.OO-OO 511.00-00 512.00-00 This responds to your application, dated December 30, 2011, requesting a ruling as to the federal tax consequences of a proposed transaction under sections 501 (c)(9) and 511 of the Internal Revenue C…
  7. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    tever source derived, including (but not limited to) the following items: ******* (11) Pensions; SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
  8. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …celing notes, and recorded by journal entries. Thus, MPC issued MIT 86 - 79 - 25 The amount of $585,511 appearing on the note was incorrect and should have been $588,511. The transaction was recorded on the books of MIT 86 and MPC in the amount of $588,511. a demand note in the amount of $585,511, 25 without interest, …
  9. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    ALS T.C. Memo. 2013-10 UNITED STATES TAX COURT THOUSAND OAKS RESIDENTIAL CARE HOME I, INC., ET AL.,' Petitioners V. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 1448-10, 1480÷10, Filed January 14, 2013. 1481-10. R determined that a corporation's compensation packages for its owner-employees were unreasonabl…
  10. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
  11. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021
    …ion required to file an annual return under section 6011 that relates to any tax imposed by section 511 to file such return in electronic form, effective for taxable years beginning after July 1, 2019. Section 3101 of the TFA does not provide for any waiver of or alternative method to the electronic-filing requirement …
  12. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989related by meaning
    e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
  13. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    … Cl. Ct. 102, 107 (1991), aff’d , 994 F.2d 839 (Fed. Cir. 1993)); see also Collman v. Commissioner, 511 F.2d 1263, 1265– 69 (9th Cir. 1975) (holding that a taxpayer had the requisite donative intent when he donated property to the county to widen the road even though he benefited from this activity because widening the…
  14. 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…
  15. 106 T.C. No. 23 — Brody Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJun 10, 1996related by meaning
    mount necessary to fund the benefits payable under section 415 determined at the time of the contribution in question. Citrus Valley Estates, Inc. v . Commissioner , 99 T.C. at 447. The dispute in these cases focuses on the amounts of benefits payable under section 415 determined at the time of the contributions in que…
  16. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  17. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
  18. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    tribution with respect to an employee under subparagraph (A) only if— (i) such amount is received on or after the employee has attained age 591/2, and (ii) the taxpayer elects for the taxable year to have all such amounts received during such taxable year so treated. Not more than 1 election may be made under this subp…
  19. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024
    …ed that the IRS received “ Form [ s ] 1099– R ” from the RRB reporting total distributions of $51 , 511 as follows: $24 , 723 with distribution code “X” (DC X) ; $18 , 119 with distribution code “ Y ” (DC Y) ; $8, 153 also with DC Y; and , $516 with distribution code “Z ” (DC Z). The notice u sed DC X to reflect the NS…
  20. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    tz v. Commissioner , supra , and Kasey v. Commissioner , supra , is also misplaced. In those cases, we held that the taxpayers constructively received income to which they were entitled but which was garnished and remitted to judgment creditors. In neither case is there any indication that the taxpayers disputed their …