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Go to I.R.C. § 993 (not yet in the library — opens the official source)
75 documents · 0.16sAllIRCERISAPBGCJoint Board
  1. 42 T.C. 993 — Barrett v. Commissioner
    IRCCourt RulingsAug 31, 1964
    OPINION 'Scott, Judge: Respondent determined a deficiency in the income tax of petitioners for the taxable year 1960 in the amount of $9,125 and an addition to the tax under section 6654 of the Internal Revenue Code of 1954 for underpayment of estimated tax in the amount of $83.95. The two issues raised by the pleading…
  2. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024
    …g 2016 . A gain a s with 2015, Mrs. Tuma’s 2016 Form 1099– R reported a gross distribution of $16 , 993 and characterized the entire amount as taxable. 6 [* 6 ] III. Petitioners’ Income Tax Reporting Petitioners jointly filed a Form 1040, U.S. Individual Income Tax Return , for each year in issue . Mr. Tuma prepared th…
  3. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ies. Subchapter C, consisting solely of section 6751, sets forth “Procedural Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…
  4. 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…
  5. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …333,233 × 8% = 26,659. Back to Citation 296.  The burden is estimated as follows: 26,659 × 90% = 23,993 uninsured (or self-pay) individuals will self-represent. 23,993 × 2 hours = 47,986 hours. A labor rate of $64.32 is used for uninsured (or self-pay) individuals (all occupations). The labor rate is applied in the fol…
  6. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    exceptions contained therein. See Recklitis v. Commissioner , 91 T.C. 874, 913 (1988); Tillman v. Commissioner , T.C. Memo. 1996-8. Because petitioner has not shown that any one of the exceptions applies, we sustain respondent's determination on this issue. IV. Section 6673--Penalty Awarded by Court We decide sua spont…
  7. 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…
  8. Treas. Reg. § 1.430(j)-1(f) — Payment of minimum required contributions.
    IRCRegulationsSep 9, 2016
    akes a contribution of $9,993 on April 10, 2016. The effective interest rate for Plan F for the 2016 plan year is 5.90%. (ii) In accordance with paragraph (c)(3)(ii) of this section, the contribution is increased for interest at the effective interest rate, for the 5 days between the contribution date and the due date …
  9. T.C. Summary Opinion 2002-108 — Claudia J. Dunn v. Commissioner
    IRCCourt RulingsAug 22, 2002
    …r education expenses for that year. In the present case, petitioner explained that she withdrew $41,993 from her qualified retirement account because she required funds to buy a car and to pay off bills in addition to paying amounts to the University of Phoenix during 1998. On this record it is clear that petitioner di…
  10. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962. To…
  11. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses. In t…
  12. 89 T.C. 1137; 89 T.C. No. 80 — Rutland v. Commissioner
    IRCCourt RulingsDec 8, 1987related by meaning
    tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
  13. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    70. On November 30, 1970, the corporation deposited the sum of $16,993.41 in the trust account at Bankers Trust Co. for the pension plan contribution. On February 18, 1971, the corporation filed its initial income tax return (Form 1120-S, U.S. Small Business Corporation Income Tax Return) for the taxable year November …
  14. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    tely $1,026,855 in U. S. currency deposited into various bank accounts during the period January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts alleging violations of customs reporting requirements. On January 9, 1992, petitioner entered into a plea a…
  15. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024★ strong match
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …
  16. 81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities
    IRCProposed Rules (FR)Proposed Apr 4, 2016related by meaning
    regulations at 31 CFR Chapter X. See 31 CFR 1010.100(e). Back to Citation 2.  31 U.S.C. 5311. Back to Citation 3.  31 U.S.C. 5318. Back to Citation 4.  Treasury Order 180-01 (Jul. 1, 2014). Back to Citation 5.  31 U.S.C. 5318(g) was added to the BSA by section 1517 of the Annunzio-Wylie Act; it was expanded by section …
  17. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    e not binding on any government agency other than the United States Department of Labor." On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise tax deficiencies pursuant to section 4975(a) and (b), as well as additions to tax. Respondent determine…
  18. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024related by meaning
    U.S.C. 987, 989, and 6001. Section 1.987-11 also issued under 26 U.S.C. 987, 989, and 1502. Section 1.987-12 also issued under 26 U.S.C. 987 and 989. Section 1.987-13 also issued under 26 U.S.C. 987 and 989. Section 1.987-14 also issued under 26 U.S.C. 987 and 989. Section 1.987-15 also issued under 26 U.S.C. 987 and …
  19. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    principles and to deter the waste of judicial resources. See Coleman v. Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, at *10. The Court has provided ample warnings to petitioners of the potential implications of continuing to assert frivolous and groundless arguments. For…
  20. Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex…
    IRCNoticesNov 13, 2007related by meaning
    g whether an estate making the section 6166 election will be required to provide security. TAX CONVENTIONS Announcement 2007-107 Announcement 2007-107 The competent authorities of the United States and the United Kingdom hereby enter into the following agreement (“the Agreement”) regarding the definition of “first noti…