IRCCourt RulingsDec 11, 1997
tment. Sec. 163(d)(3)(A).
In general, interest expense on a debt is allocated in the
same manner as the debt to which such interest expense relates is allocated. Debt is allocated by tracing disbursements of the
debt proceeds to specific expenditures. Sec. 1.163-8T(a)(3),
Temporary Income Tax Regs., 52 Fed. Reg. 24999 …
Notice 2024-35 — This notice provides relief with respect to certain required minimum distributions (RMDs) that are not made in 2024. This relief was provided with respect to c… IRCNoticesMay 6, 2024
… and Kathleen Hannick (2020). “Fixed Indemnity Coverage is a Problematic Form of “Junk” Insurance,” USC-Brookings Schaeffer Initiative for Health Policy, available at: https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-insuran…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…umed by MVL , which it later satisfied, including
accrued interest .
A. Statutory Framework
Section 163( a ) allows a deduction for interest paid or accrued
within the taxable year on inde btedness. For noncorporate taxpayers,
however, section 163(h)(1) disallows a deduction for personal interest.
Personal interest doe…
IRCCourt RulingsApr 16, 2026
…80 ,000 Policy Loan
Individual taxpayers may deduct interest other than personal
interest. I.R.C. § 163 (a), (h)(1). In relevant part, interest other than
personal interest includes , among other things, trade or business
interest and investment interest. I.R.C. § 163(h)(2)(A) and (B); s ee also
Atwood , 77 T.C.M. (CCH…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…
See
Hannick, Kathleen and Loren Adler. “Provider Charges Relative to Medicare Rates, 2012-2018.” USC-Brookings Schaeffer on Health Policy. (May 2021).
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/05/03/provider-charges-relative-to-medicare-rates-2012-2018/.
Back to Citation
210…
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, 2024related by meaning
—Shared Responsibility for Employers Regarding Health Coverage.—Whether an employer is required to make an assessable payment under § 4980H(a) or (b). (136) Section 6050P.—Returns Relating to the Cancellation of Indebtedness by Certain Entities.—Requests for a ruling that the creditor is not required to report a discha…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
er 1 as determined under subsection (e)
by substituting —
(i) in paragraph (1)(A), “200 percent”
for “150 percent” . . . .
2. Section 6662: Discussion Section 6662(a) is a generally applicable provision through which
all accuracy-related penalties are imposed on underpayments of tax.
Section 6662(b) lists the penalizab…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…hleen Hannick (2020). “Fixed Indemnity Health Coverage Is a Problematic Form of `Junk Insurance,' ” USC-Brookings Schaeffer Initiative for Health Policy, available at:
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2020/08/04/fixed-indemnity-health-coverage-is-a-problematic-form-of-junk-i…
IRCCourt RulingsJun 14, 2012related by meaning
ess doctrine, courts may invalidate laws if "'men of common
intelligence must necessarily guess at its meaning.'" Ick (quoting Hynes v. Mayor
- - 45 - of Oradell, 425 U.S. 610, 620 (1976)); see also United States v. Derezinski, 945
F.2d 1006, 1010 (8th Cir. 1991). It is apparent that Notice 2004-8, supra
addresses tran…
75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Jun 16, 2010related by meaning
URE AND ADMINISTRATION
Paragraph 1.
The authority citation for part 301 continues to read in part as follows:
Authority:
26 U.S.C. 7805 * * *.
Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows:
§ 301.6404-0
Table of Contents.
* * * * *
§ 301.6404-4 Suspension of interest and c…
IRCCourt RulingsJan 2, 2020related by meaning
er. Mrs. Gebman did not provide any evidence that persuades us that
she meets the requirements for relief. Accordingly, Mrs. Gebman is not entitled to relief under section 6015(f), and we will deny her motion for leave to file
amendment to petition filed August 28, 2019.
VI. Section 6662(a) Penalties
Section 6662(a) an…
IRCCourt RulingsSep 15, 2005related by meaning
Court, the two cases were
consolidated for hearing on the motions to dismiss. The hearing
was held on November 29, 2004, in San Francisco, California. Discussion
Section 6033(a)(1) requires an organization exempt from
taxation under section 501(a) to file."an annual return, stating
specifically the ite s of gross incom…
IRCCourt RulingsMar 31, 2005
interest is excluded from the
definition of personal interest and thus is deductible under
section 163(a). See sec. 163(h)(2)(D). Qualified residence interest is any interest which is paid or accrued during the
taxable year on acquisition indebtedness or home equity
indebtedness. See sec. 163(h)(3)(A). Acquisition ind…
IRCCourt RulingsAug 1, 2012related by meaning
ich they rely to reduce the taxable amounts of the distributions
that they received in 2007. Thus all of the distributions are included in their gross income and taxed as ordinary income. The amounts previously reported as capital
gains will be eliminated in the Rule 155 computation in accordance with
respondent's conc…
IRCCourt RulingsDec 20, 2001
marize the pertinent
law.
Section 163(a) generally allows a deduction for all interest
paid or accrued during the taxable year on indebtedness. In the case of a taxpayer other than a corporation, section 163(h)
generally disallows any deduction for “personal interest”. The
term “personal interest” is defined to mean an…
IRCCode / StatuteJan 24, 2020related by meaning
(c)(2)(C) (C) Split-interest trusts In the case of a trust which is required to file a return under section 6034(a), subparagraphs (A) and (B) of this paragraph shall not apply and paragraph (1) shall apply in the same manner as if such return were required under section 6033, except that— In addition to any penalty im…
IRCCourt RulingsJan 5, 2017related by meaning
ably with the Code, but also negligence and a clear disregard of
rules or regulations. Petitioner did not act with reasonable cause and in good faith. Accordingly, the Court holds that petitioner is liable for accuracy-related penalties
under section 6662(a) for the 2010 and 2011 tax years.
- 15 -
[*15] VII. Section 66…
IRCFinal Rules (FR)Nov 8, 2011related by meaning
sthroughs and Special Industries), IRS.
List of Subjects in 26 CFR Part 20
Estate taxes
Reporting and recordkeeping requirements
( printed page 69128) Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 20 is amended as follows:
PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954
Paragra…
IRCCourt RulingsNov 12, 1997
…er argues that
s uch amount, to the extent substantiated,
6
should be allowe d
pursuant to secti on 163 as interest incurred in the conduct of a
trade or business. Respondent asserts that petitioner's interest
expense deductions are for investment interest and therefore are
limited to net investment income pursuant to …
IRCCourt RulingsJun 6, 2016
tion to this general rule, however, in the case of a taxpayer other than
a corporation, section 163(h) generally disallows any deduction for "personal interest", defined to include any interest expense that does not fall within one of
the five categories listed in section 163(h)(2). These categories are: (1) trade or
b…