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79 documents · 0.15sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  2. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    f the adopted TAM to the taxpayer, or at the end of the 30-day period following the issuance of the TAM to the field. Discussion with the taxpayer .03 EP or EO Technical will not discuss the contents of the TAM with the taxpayer or the taxpayer’s representative until the taxpayer has been given a copy by the EP or EO E…
  3. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
  4. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    or documents to which § 6104 (document open to public inspection) applies, as described in section 10.03. Taxpayer may protest deletions not made .05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
  5. 131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner
    IRCCourt RulingsSep 10, 2008
    … were payments made 'in connection with' the redemption of the convertible preferred stock." Id. at 757. In a nutshell, Boise Cascade Corp. appears to proceed on the premise that if distribution payments to the withdrawing ESOP participants are made "in connection with" redemption of stock, then section 162(k) disallow…
  6. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996related by meaning
    easing arrangements with the promise of substantial tax advantages. The participants-- Bucci, Machise, the investors and the partnerships--did as they were told by Fred and Bruce and accepted the figures provided in memoranda from BBPA. They understood that Fred and Bruce would attend to the details, but Fred, and to s…
  7. T.C. Memo. 1998-145 — Estate of Hilda Ashman, Deceased; Phillip Ashman, Personal Representative v. Commissioner
    IRCCourt RulingsApr 22, 1998
    …affects his or her tax liability for an open year. E.g., Herrington v. Commissioner , 854 F.2d 755, 757 (5th Cir. 1988), affg. Glass v. Commissioner , 87 T.C. 1087 (1986); LeFever v. Commissioner , 103 T.C. 525, 541-542 (1994), affd. 100 F.3d 778 (10th Cir. 1996). The duty of consistency applies when: (1) The taxpayer …
  8. 75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac…
    IRCFinal Rules (FR)Jul 6, 2010related by meaning
    sactions to which a tax-exempt entity is a party. Section 516 of TIPRA added new section 4965 and amended sections 6033(a)(2) and 6011(g) of the Code. On July 6, 2007, the IRS and the Treasury Department published final and temporary regulations under sections 6011 and 6071 (TD 9334) and temporary regulations under sec…
  9. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024
    …2,412 $194,351 $153,593 Dividend income 30 46 62 200 200 200 Interest income 465 13,610 2,479 1,055 757 988 2. Whether p etitioners failed to report p ension and a nnuity income of $97,921 for tax year 2000; 3. Whether p etitioners are entitled to deduction s for taxes paid and mortgage interest claimed on Schedule A, …
  10. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    …nference of Commissioners on Uniform State Laws, August, 1985; Restatement (First) of Torts section 757 (1939). Back to Citation 105.  Restatement (First) of Torts section 757 (1939) (“ GENERAL PRINCIPLE.
  11. U.S. Tax Court — Marlon G. Dasent & Kendra Walcott-Dasent v. Commissioner
    IRCCourt RulingsDec 13, 2018
    …haring Plans, IRAs, Insurance Contracts, etc., for 2014, reflecting distributions of $7,865 and $17,757, respectively, as early distributions with "no
  12. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …er. The labor rates are applied in the following calculation: 26,659 claims × 1 hour × $140.96 = $3,757,798. The total annual response time cost estimates are added as follows: $3,267,013 + $3,757,798 = $7,024,811. The total burden hours are 53,317. Back to Citation 300.  The burden is estimated as follows: 26,659 clai…
  13. T.C. Memo. 2007-90 — Roger F. & Mary A. Duronio v. Commissioner
    IRCCourt RulingsApr 17, 2007related by meaning
    iable for the $1,990 10-percent additional tax on the $19,900 early IRA distribution Mary received. To reflect the foregoing, Decision will be entered under Rule 155 .
  14. T.C. Memo. 2010-20 — Gregory A. & Carolyn S. Prough v. Commissioner
    IRCCourt RulingsFeb 3, 2010
    …ot indicate how the $1,400 monthly amount was calculated . Nationwide determined that a maximum of $757 could be withdrawn per month .if the distributions were to qualify for an exception to section 72(t) . Nationwide started making the $1,400 monthly distributions to petitioner on August 17, 2003 . The Nationwide annu…
  15. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM November 21, 2005 Third Party Communication: None Date of Communication: Not Applicable Number: 200610016 Release Date: 3/10/2006 Index (UIL) No.: 832.09-00, 404.11-00, 446.04-00 CASE-MIS No.: TAM- 134113-05/CC:FIP:B4 --------------------------------…
  16. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …olved. Here , some of the factors 20 See § 7463(b) ; Rule 170; Golsen v. Commissioner, 54 T.C. 742, 757 (1970), aff’ d , 445 F.2d 985 (10th Cir. 1971). 22 do not apply or are neutral . No single factor or group of factors is dispositive , and more weight may be given to some factors than others. Golanty , 72 T.C. at 42…
  17. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007related by meaning
    nership’s activities lacked economic substance. The taxpayer has now offered to compromise all the penalties and interest on terms more favorable than those contained in the prior settlement offer, arguing that TEFRA is unfair and that the liabilities accrued in large part due to the actions of the Tax Matters Partner …
  18. T.C. Memo. 2026-93 — Aloke Pal v. Commissioner
    IRCCourt RulingsSep 24, 2026
    …ppeal of this case would generally lie. See § 7482(b)(1)(G) ; Golsen v. Commissioner , 54 T.C. 742, 757 (1970), aff ’ d , 445 F.2d 985 (10th Cir. 1971). Once the Commissioner satisfies his burden of production, the taxpayer bears the burden of proving that the Commissioner’s determination is incorrect or that the taxpa…
  19. 89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern
    IRCFinal Rules (FR)May 6, 2024related by meaning
    's written reports to the IRS. The procedures for such periodic written reports are established in guidance published in the Internal Revenue Bulletin (see § 601.601 of this chapter). To the extent a taxpayer relies on certifications or attestations from the qualified manufacturer regarding certain section 30D requirem…
  20. 56 T.C. 263 — Smith v. Comm'r
    IRCCourt RulingsMay 12, 1971★ strong match
    …hul Tobacco Co. v. Commissioner, 42 F. 2d 609, 610 (C.A. 5) ; Hughes v. Commissioner, 38 F. 2d 755, 757 (C.A. 10) ; John I. Chipley, 25 B.T.A. 1103, 1106; Edgar M. Carnrick, 21 B.T.A. 12, 21; cf. Helvering v. Rankin, 295 U.S. 123, 132-133.”