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 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…
81 FR 13305 — Definition of Political Subdivision; Correction IRCProposed Rules (FR)Proposed Mar 14, 2016
…ations of a political subdivision under section 103 but also for other purposes of sections 103 and 141 through 150. Commenters explained that, without a transition rule for the private activity bond rules under section 141, certain bonds issued before the notice of proposed rulemaking and notice of public hearing was …
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 RulingsJul 31, 2000★ strong match
…of $106,353. At the time of conversion, the C-group term
policy’s conversion credit balance was $58,141.90, and $55,234.80
of that amount ($58,141.90 x 95%) was transferred to the C-group
conversion UL policy for potential earning. Dr. Desai will earn
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
… that will not exceed the yield on the state or local bonds prior to their expenditure. (8) Section 141.—Private Activity Bond; Qualified Bond.—Whether state or local bonds will meet the “private business use test” and the “private security or payment test” under § 141(b)(1) and (2) in situations in which the proceeds …
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1996-450
UNITED STATES TAX COURT
THEODORE SOURIS, P.C., A DISSOLVED CORPORATION,
AND THEODORE SOURIS, AS SUCCESSOR IN INTEREST
OF THEODORE SOURIS, P.C., Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 639-95. F…
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
…satory damages, punitive damages, etc. is a proper allocation for federal tax purposes.
(8) Section 141.—Private Activity Bond; Qualified Bond.—Whether state or local bonds will meet the “private business use test” and the “private security or payment test” under §141(b)(1) and (2) in situations in which the proceeds a…
IRCCourt RulingsJan 20, 1983related by meaning
sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
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
…tory damages, punitive damages, etc., is a proper allocation for federal tax purposes.
(8) Sections 141.—Private Activity Bond; Qualified Bond.—Whether state or local bonds will meet the “private business use test” and the “private security or payment test” under §141(b)(1) and (2) in situations in which the proceeds a…
IRCCourt RulingsJul 25, 2012
…st file a return in order to elect to itemize
deductions. See Jahn v. Commissioner, T.C. Memo. 2008-141, 2008 Tax Ct.
Memo LEXIS 141, at *2, aff'd, 392 Fed. Appx. 949, 950 (3d Cir. 2010); Brunner
v. Commissioner, T.C. Memo. 2004-187, 2004 Tax Ct. Memo LEXIS 193, at *10,
aff'd, 142 Fed. Appx. 53 (3d Cir. 2005). If a tax…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsJan 14, 2013related by meaning
… Valley Estates, Inc. v.
Commissioner, 99 T.C. 379 (1992), aff'd in part, remanded in part, 49 F.3d 1410
(9th Cir. 1995). Because we found supra that a portion of TORCH's contributions to
the pension plan was unreasonable compensation and therefore not deductible under
section 162 (and thereby section 404), the 10% sec…
IRCCourt RulingsNov 6, 1962related by meaning
ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated.
Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act.
Thls section was originally desi…
IRCCourt RulingsApr 2, 2020
…011 . . . . . 140
GG. Period 20: March 29 through April 15, 201 1 . . . . . . . . . . . . . . . . . 141
1. Introduction...................................... 141
2. Events .......................................... 142
3. Analysis and holding............................... 143
HH. Intermediary period: April 16-28, 201 …
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…opted pursuant to the authority contained in sections 7805 and 9833 of the Code, and Public Law 103-141, 107 Stat. 1488 (42 U.S.C. 2000bb-2000bb-4). The Department of Labor regulations are adopted pursuant to the authority contained in 29 U.S.C. 1002(16), 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCFinal Rules (FR)Dec 30, 2024
…The proposed regulations provide that a tax-exempt bond is retired for purposes of sections 103 and 141 through 150 when a significant modification occurs under § 1.1001-3. Section 1.1001-3(e)(5)(i) generally provides that, subject to the special rule in § 1.1001-3(f)(7), a modification of a debt instrument that result…
IRCCourt RulingsMay 20, 1976related by meaning
tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty.
OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…2, 2003-2 C.B. 559; Notice 2002-45, 2002-2 C.B. 93; Rev. Rul. 2002-41, 2002-2 C.B. 75; Rev. Rul. 69-141, 1969-1 C.B. 48. New section 106(e) provides that a health FSA will not fail to satisfy the requirements of sections 105 or 106 merely because the plan provides for a qualified HSA distribution. Amounts rolled into a…