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)…
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 …
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…
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…
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…
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…
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…
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,
…
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…
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…
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 …
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…
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…
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 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…
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 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…
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…
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…
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 …