IRCCourt RulingsFeb 9, 2023★ strong match
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsSep 24, 2007
…41 deficiency for petitioner's 2002 taxable
year . The issues for decision are :
(1) Whether a $168,355 pension distribution to petitioner in
2002 pursuant to a qualified domestic relations order (QDRO) is
includable in petitioner's 2002 taxable income ;
(2) whether $8,119 .20 of the $9,552 in Social Security
benefits …
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…engages in commercial activity with respect to the real property interest transferred. (28) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
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 RulingsFeb 6, 2024
…ioner ,
50 T.C. 585, 592 (1968 ) ) ; accord Benes v. Commissioner, 42 T.C. 358, 381
(1964), aff’d , 355 F.2d 929 (6th Cir. 1966) ; see also Corliss, 281 U.S.
at 378; Treas. Reg. § 1.451-2(a). As discussed below, t his Court has
consistently applied the constructive receipt doctrine in cases where the
taxpayer’s assets …
IRCRegulationsJan 19, 2017
…plicable with respect to stock acquired by a distribution or an exchange to which section 305, 354, 355, 356, or 1036 (or so much of section 1031 as relates to section 1036) applies. Stock so acquired shall, for purposes of sections 421 through 424, be considered as having been transferred to the individual upon his ex…
IRCProposed Rules (FR)Proposed Dec 23, 2025
s in an annual storage savings of roughly $57,355,200 [210]
for the 300 third-party developers and other files users based on file-size optimizations. However, because these proposed rules also shift the reporting frequency from monthly to quarterly, total storage needs and corresponding savings would be reduced accord…
IRCCourt RulingsDec 18, 2012★ strong match
0- (1,561) -0-
(3,763) (2,116) -0-
-0- (1.461) -016,087 15,355 19,542
Respondent determined that each petitioner realized one-half of the total rental income for 1995, 1996, and 1997. These amounts are as follows:
1995 1996 1997
Deposited rent $17,908 $41,810 $2,730
Additional rent 16,087 15,355 19,542
Total rent 33,99…
IRCCourt RulingsJan 3, 2011
…of thee$36,000 was credited towards the
cash value of petitioner' s life insurance policy. The $17, 355
excess contribution was not credited toward the cash value of the
life insurance policy covering petitioner discussed in the PERC
valuation above . Consequently, the inclusion of the excess
contribution in petitioner…
T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner IRCCourt RulingsJan 19, 2016★ strong match
…829, 29 U.S.C. sec. 1001 (2006), and the Internal Revenue Code in Gallade
v. Commissioner, 106 T.C. 355, 361 (1996), as follows:
ERISA was enacted to establish "a comprehensive federal
scheme for the protection of pension plan participants and their
beneficiaries." American Tel. & Tel. Co. v. Merry, 592 F.2d 118, 120
(…
IRCCourt RulingsFeb 28, 2024related by meaning
stituting a 6-year period in lieu of the 3-year
period otherwise referred to in such subsection.
(D) Exception for certain acquisitions of property. — In the case of any tax imposed by section 4973 that is attributable to acquiring property for less than fair market
value, subparagraph (A) shall not apply.
Section 313(…
IRCCourt RulingsJul 31, 2000
…of that year, the conversion credit balance was $124,364.78 ($77,954.39 + $53,150 - $12,095.03 + $5,355.42); the
$5,355.42 is the interest of 4.5 percent earned on the conversion
credit balance (($124,364.78 - $5,355.42) x 4.5% = $5,355.42)).
Of the conversion credit balance, $112,239.22 could have been
transferred at …
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
…engages in commercial activity with respect to the real property interest transferred.
(29) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
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
…engages in commercial activity with respect to the real property interest transferred.
(29) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
IRCRegulationsJul 12, 2016
… 15% of $100,000=) 115,000 120,000 1982 500,000 (20% of $500,000=) 100,000 100,000 Totals 1,800,000 355,000 420,000 (2) Organization X, whose taxable year is the calendar year, was organized in 1971. X first made the expenditure test election under section 501(h) effective for taxable years beginning with 1979 and has …
T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner IRCCourt RulingsFeb 2, 2022
… of the Estate was $212,267.
6
He also determined that
only a portion of the Estate’s expenses ($91,355) was va lid and senior to
its unpaid f ederal tax liability.
7
These two determinations resulted in a
reasonable collection potential of $120,912. Appeals Officer Duff noted
that he would not decrease the Estate’s re…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
IRCCourt RulingsJul 6, 2022related by meaning
s
are to the Tax Court Rules of Practice and Procedure.
Served 07/06/22
2
[* 2 ] under section 4973, plus associated additions to tax and penalties.
2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as
a matter of law from asserting …