IRCCourt RulingsFeb 9, 2023related by meaning
nly if
the restriction is in writing. Taking unwritten restrictions into account
in determining section 482 allocations wo uld foster disputes between taxpayers and the Internal Revenue Service as to the substance of
unwritten rules made by foreign governments. Furthermore, there
would be uncertainty in the computation…
IRCCourt RulingsFeb 28, 2024related by meaning
years
beginning after the date of enactment of the Act); id. § 311(b)(2), 136
Stat. at 5347 (providing that qualified birth or adoption distributions made on or before the date of enactment of the Act will have a threeyear period of limit ations from the date the distribution was received).
“This is the highly reticul…
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
IRCCourt RulingsAug 4, 1983
…s use is merely incidental thereto.” Fairfax Mutual Wood Products Co. v. Commissioner, 5 T.C. 1279, 1282 (1945) (involving the manufacture of furniture parts to the specifications of customers).
IRCCourt RulingsDec 11, 2003related by meaning
h the “objective of the safe
harbor provision” referred to by the Court of Appeals in Evans
Cooperage
. Petitioner’s failure to file a return prior to respondent’s issuance of the notice presents us with a situation
that is the exact opposite of that referred to in Evans
Cooperage
, where the filing of returns preceded…
IRCPrivate Letter RulingsJun 17, 2016
…the same taxpayer,
qualifies as a tax-free exchange under § 1035.
In Rev. Rul. 2007-24, 2007-1 C.B. 1282, insurance company one disbursed a
check representing a surre nder of old non-qualified annuity policy to taxpayer who, in
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 3, 1995
…ming and amount of employer deductions for contributions. * * *
[H. Rept. 98-432 (Part 2), supra at 1282-1283; emphasis added.]
In light of the legislative history, we agree with the staff of the Joint Committee on Taxation that
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
IRCPrivate Letter RulingsJul 26, 2013
…72) as income in
re spect of a decedent within the meaning of § 691.
Rev. Rul. 2007-24, 2007-1 C.B. 1282, holds that if a taxpayer receives a check from a
life insurance company under a non-qualified annuity contract, the endorsement of the
check to a second company as consi deration for a second annuity contract does …
IRCCourt RulingsMay 22, 2008related by meaning
Internal Revenue Code .
Accordingly, petitioner is liable for the section 6662 penalty .
In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is
i
6 -
imposed upon such distributions unless the distributions meet the
requirements of one of the exce…
IRCPrivate Letter RulingsDec 1, 2006
…le in decedent’s gross under sections 2036 and 2038. In Estate of Wylie v.
Commissioner
, 610 F. 2d 1282, 1290-1291 (5
th
Cir. 1980), the court summarized the purpose of
section 2036, as follows :
The purpose of this provision is to prevent circumvention of federal estate tax by
u se of inter vivos schemes which do not…
IRCCourt RulingsAug 24, 2000
…ership’s taxable year begins upon the date it is formed. See Sparks v. Commissioner
, 87 T.C. 1279, 1282 (1986).
A partnership is formed “when the parties to a venture join
together capital or services with the intent of conducting
presently an enterprise or business.” Id.
Whether SLA was
formed prior to September 4, 1…
IRCCourt RulingsJul 2, 2002
…ircumstances. Boehm v. Commissioner
, 326 U.S. 287, 293 (1945);
Dallmeyer v. Commissioner , 14 T.C. 1282, 1291 (1950).
Petitioner contends he had two grounds for concluding the
Atascadero loan was worthless in 1995. First, he argues that
Stephanie’s financial condition in 1995 had deteriorated to the
point where he wou…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
IRCCourt RulingsJul 13, 2015related by meaning
claimed medical transportation expenses and that he falls under the
exception in section 72(t)(2)(B). As discussed supra Part II.A, petitioner is not entitled to deduct his claimed medical transportation expenses under section
213(a). Therefore, he does not fall under the exception in section 72(t)(2)(B) and
he is lia…
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
38 T.C. 915 — Commercial Fishermen's Inter-Insurance Exchange v. Commissioner IRCCourt RulingsSep 21, 1962
…F. 2d 46 (C.A. 2, 1933), affirming a Memorandum Opinion of this Court; and W. A. Dallmeyer, 14 T.C. 1282 (1950). We sustain respondent in his position that the $53,219.63 of reinsurance claimed by petitioner from SNAR is not deductible by petitioner in computing its 1957 net operating loss carry-back to the year 1955.
IRCCourt RulingsDec 29, 2005related by meaning
lusion, we need not decide
respondent's contention regarding the fact that petitioner did
not receive a determination from the United States competent authority as to whether the French retirement plan generally
corresponds to a United States retirement plan or that certain
documents, including Exhibits 9-P and 12-P, a…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
…y of Patients' Experiences Selecting Telehealth Versus In-Person Care,
42(9) Health Affairs pp 1275-1282 (2023).
Back to Citation
375.
Code section 9812(a)(8)(A)(i), ERISA section 712(a)(8)(A)(i), and PHS Act section 2726(a)(8)(A)(i).
Back to Citation
376.
Code section 9812(a)(8)(A)(ii), ERISA section 712(a)(8)(A)(ii…