IRCCourt RulingsFeb 9, 2023related by meaning
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsOct 12, 1978related by meaning
do not deal with the operations of the plan, there is a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comm…
IRCRegulationsSep 9, 2016
…date. In this case, the straight life annuity payable under the plan commencing at the same age is $152,619. Because the plan's factors for actuarial equivalence in this case are the same standardized actuarial factors required to be applied to determine the actuarially equivalent straight life annuity, the actuarially…
IRCCourt RulingsJan 13, 2003
odial parent. Sec. 152(e)(2).
more than half of whose support during the calendar year is
provided for by the taxpayer, are “dependents”. Sec. 152(a). Section 152(e)(1), however, further provides that if a child
receives more than half of his support during the calendar year
from parents who are divorced or legally sep…
T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.… IRCTreasury DecisionsApr 30, 2007
…date. In this case, the straight life annuity payable under the plan commencing at the same age is $152,619. Because the plan’s factors for actuarial equivalence in this case are the same standardized actuarial factors required to be applied to determine the actuarially equivalent straight life annuity, the actuarially…
REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie… IRCProposed Rules (FR)Proposed Jul 5, 2005
…able. In this case, the straight life annuity payable under the plan commencing at the same age is $152,619. Because the plan’s factors for actuarial equivalence in this case are the same standardized actuarial factors required to be applied to determine the actuarially equivalent straight life annuity, the actuarially…
IRCPrivate Letter RulingsFeb 2, 2018
… (a s defined in
section 213(d)) of the taxpayer, his spouse, his dependents (as defined in section 152,
determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof), and any
child (as defined in section 152(f)(1)) of the taxpayer who as of the end of the taxable
year has not attained age 27. Any chi…
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017
Rev. Proc. 2017–4
TABLE OF CONTENTS
SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE?
152
.01 Purpose of revenue procedure
152
.02 Organization of revenue procedure.
152
.03 Other guidance affecting this revenue procedure
152
.04 Updated annually
152
>SECTION 2. WHAT CHANGES HAVE BEEN MADE TO THIS REVENUE PROCE…
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…
IRCCourt RulingsJul 30, 1985related by meaning
Eanes as petitioner.
In his answer, filed May 2,1985, respondent claimed an increased deficiency of $90 in excise tax pursuant to secs. 4973 and 6214. Sec. 219 has been amended to allow persons covered by qualified plans to take deductions for contributions to IRA’s in taxable years beginning after Dec. 31, 1981. See s…
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…
IRCPrivate Letter RulingsAug 23, 2024
…l care (as
defined in section 213(d)) of the taxpayer, spouse, or dependents (as defined in section
152, determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof) and
any child (as defined in section 152(f)(1)) who has not attained age 27 as of the end of
the taxable year.
Treas. Reg § 1.105-2 pro…
IRCPrivate Letter RulingsJun 5, 2020
…ed in section 213(d)) of the taxpayer or the taxpayer’s spouse or dependents (as defined in section 152, determined with out regard to subsections (b)(1), (b)(2), and
(d)(1)(B)) and any child (as defined in section 152(f)(1)) who has not attained age 27 as
of the end of the taxable year. Section 1.105-2 provides that o…
IRCPrivate Letter RulingsSep 23, 2016
…e (as defined in
section 213(d)) of the taxpayer, his spouse, his dependents (as defined in section 152,
determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof), and any
child (as defined in section 152(f)(1)) of the taxpayer who as of the end of the taxable
year has not attained age 27. Any chi…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
IRCRegulationsMay 18, 2016
…use, the service provider's beneficiary, or the service provider's dependent (as defined in section 152, without regard to section 152(b)(1), (b)(2), and (d)(1)(B)); loss of the service provider's property due to casualty (including the need to rebuild a home following damage to a home not otherwise covered by insuranc…
IRCCourt RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
IRCRegulationsNov 17, 2025
…ry education for the employee, for the employee's spouse, child or dependent (as defined in section 152 without regard to section 152(b)(1), (b)(2) and (d)(1)(B)), or for a primary beneficiary under the plan; (4) Payments necessary to prevent the eviction of the employee from the employee's principal residence or forec…
76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner IRCCourt RulingsMar 17, 1981related by meaning
implement the congressional mandate in some reasonable manner.’ ” (Citations omitted.) Commissioner v. Portland Cement Co. of Utah, 450 U.S. _ (1981). H. Rept. 2333,77th Cong., 1st Sess. (1942), 1942-2 C.B. 372,413; S. Rept. 1631, 77th Cong., 2d Sess. (1942), 1942-2 C.B. 541, 606-607. The specific changes made by Congr…