82 FR 47792 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
… 47827) final rules as well as the related requirements currently approved under 0938-1292 and 0938-1248. In an effort to consolidate the number of information collection requests, we will formally discontinue the control numbers 0938-1292 and 0938-1248 once the new information collection request associated with these …
IRCCourt RulingsFeb 9, 2023related by meaning
arties at the original contract date.” Notice 88-123,
1988- 2 C.B. at 477.
145
JJ. T
he 1988 amendment to section 7805 regarding temporary
regulations In 1988, Congress added section 7805(e), which provided:
SEC. 7805 (e). Temporary Regulations. --
(1) Issuance. --Any temporary regulation
issued by the Secretary shall …
82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…he burden for these ICRs is accounted for in the collection approved under OMB Control Numbers 0938-1248 and 0938-1292, as described in the interim final rules concerning religious beliefs issued contemporaneously with these interim final rules.
We are soliciting comments on all of the possible information collection r…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
g a portion of the claimed rebates. As respects the claim of the Georgia company the petitioner is before us as successor in interest of that company. The petitioner and the Georgia and Mississippi companies each held certificates of necessity covering emergency facilities and claimed amortization deductions with respe…
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 RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
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 RulingsFeb 28, 2024related by meaning
by the decision of the Tax Court which has become final shall be assessed and
shall be paid upon notice and demand from the Secretary .”). In short,
5 For a discussion of the disputed issues of fact on this point, see the Order
issued by the Court on April 8, 2019, denying each party’s Motion for Partial Summary
Judgme…
IRCCourt RulingsDec 9, 1971
…ons. Mississippi River Fuel Corporation v. Koehler, 266 F. 2d 190 (C.A. 8, 1959), affirming 29 T.C. 1248 (1958) and 164 F. Supp. 844 (D. Mo. 1958), certiorari denied 361 U.S. 827 (1959).
IRCCourt RulingsAug 25, 1997related by meaning
motion for costs
was filed out of time and should be "dismissed" for that reason.
We reject respondent's contention and do not consider it further.
12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA),
Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is
generally applicable to proceedings commenced after …
80 FR 41318 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Jul 14, 2015
…ds. The burden related to this alternate notice is currently approved under OMB Control Number 0938-1248.
IRCPrivate Letter RulingsDec 1, 2006
…ent made with an extension request is considered a payment of tax. Dantzler v.
U.S.
,183 F.3d 1247, 1248 (11th Cir. 1999). See
also
, David v. United States
, 964 F. Supp. 31
(D. Mass. 1997) (A remittance filed contemporaneously with a request for an extension is a
payment, not a deposit, particularly when the remittan…
IRCCourt RulingsAug 12, 1998
…
, 848 F.2d
81, 84 (6th Cir. 1988), affg. 87 T.C. 1294 (1986); Propstra v.
United States
, 680 F.2d 1248, 1256-1257 (9th Cir. 1982).
(continued...)
those employees or beneficiaries. "[T]he phrase 'purposes other
than for the exclusive benefit of his employees or their
beneficiaries' includes all objects or aims not sol…
PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans IRCPrivate Letter RulingsAug 8, 2014related by meaning
TAX EXEMPT AND
GOVERNMENT ENTITIES
DIVISION
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
MAY 13 2014
Uniform Issue List: 408.03-00, 2501.00-00, 4973.00-00, 4974.00-00
* * *
* * *
* * *
Legend:
Taxpayer A
=
* * *
Decedent 8
=
* * *
Decedent c
=
* * *
Charity D
=
* * *
Trust
=
* * *
Financia…
IRCCourt RulingsSep 13, 1990★ strong match
… to [receive] the maximum amount of property qualifying for the marital deduction." 55 T.C.M. 1246, 1248, 57 P-H Memo T.C. par. 88,296 at 1506, 1508.*108 We find this analysis to be incomplete.
The formulas in Estate of Blair and the present case initially provide that each surviving spouse is to receive the maximum ma…
IRCCourt RulingsMar 27, 1963
…triction to make inapplicable the doctrine of constructive receipt {Estate of W. T. Hales, sufra at 1248).
With regard to amounts earned by petitioner on dividends left on deposit with the respective insurance companies, we find that such amounts are properly denoted as interest and, upon the periodic crediting of such…
IRCCourt RulingsMay 28, 1962related by meaning
ion of the period allowed by the statute for such payment), by cash, check, note, property, or otherwise. Cf. Campbell Chain Co., 16 T.C. 1402 (1951). In the instant case it is clear that petitioner had no motive of tax avoidance in not making the payment within the prescribed time. Likewise no motive of tax avoidance …
IRCCourt RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026related by meaning
on 6662A.
After the parties’ filing of Stipulations of Settled Issues,
2
the
issues remaining for consideration are (1) the fair market value of the
1 Unless otherwise indicated, statutory references are to the Internal Revenue
Code, Title 26 U.S.C. (Code), in effect at all relevant times, regulation references are
to …
IRCCourt RulingsSep 22, 1998related by meaning
te minus amounts received before such date to
the extent excludible from gross income. Sec. 72(e)(6).
The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to
him of income and as the parties have agreed is subject to the
10-percent premature distribution tax und…