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 RulingsFeb 22, 1989related by meaning
the text of TEFRA section 252. See Gunther v. Commissioner, 92 T.C. 39, 56-57, 60, 64-65 (1989); Pallottini v. Commissioner, 90 T.C. 498, 503 (1988). If we may paraphrase the conclusion and direction of the Supreme Court in Aaron v. SEC, 446 U.S. 680, 700 (1980), “It seems clear, therefore, that the legislative histor…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…n sometimes lead to price alignment or collusion, which may increase prices rather than lower them.[235]
IRCCourt RulingsJul 11, 2024
spouse
may also be entitled to have their Social S ecurity benefits paid by the
RRB. 20 C.F.R. §§ 235.1– 235.4 ( 2016). If the SSA determines that the employee or his spouse is entitled to Social Security benefits and the
employee has been credited with at least 120 months of service, the SSA
certifies such benefits to…
IRCProposed Rules (FR)Proposed Oct 15, 2007
…ant to paragraph (b)(4) of this section, the funding standard carryover balance is increased to $51,235 as of July 1, 2009 (that is, an increase to reflect 6 months of interest at an effective interest rate of 5%). Sponsor T does not elect in 2009 to reduce any portion of the funding standard carryover balance pursuant…
Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023
… may be granted if justified
234
.11 Case closed if taxpayer does not submit additional information
235
.12 Near the completion of the ruling process, advises taxpayer of conclusions and, if Employee Plans Rulings and Agreements will rule adversely, offers the taxpayer the opportunity to withdraw the letter ruling requ…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent.
Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
REG-148326-05 — Proposed regulations address the calculation of amounts includible in income under section 409A(a) of the Code and the additional taxes imposed by such section… IRCProposed Rules (FR)Proposed Dec 22, 2008
…tical underpayment for such year.
Example 2.
Year 1 Year 2 Year 3 Year 4
Opening Total Amount 0 110 235 365
Bonus Deferral 100 150 200 250
Net Gains (Losses) 10 (25) (30) 25
Payments 0 0 (40) (50)
Closing Total Amount 110 235 365 590
(i) The amount that is includible in income under section 409A(a) for Year 4 is the cl…
50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner IRCCourt RulingsMay 29, 1968related by meaning
-10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
Rev. Proc. 2026-4 — This revenue procedure contains updates relating to the types of advice the Internal Revenue Service provides to taxpayers on issues under the jurisdiction of … IRCRevenue ProceduresModified Dec 29, 2025
…ed without reliance on the letter ruling
234
.10 Taxpayer may request that retroactivity be limited
235
PART IV. USER FEES
SECTION 30. WHAT ARE THE USER FEE REQUIREMENTS FOR REQUESTING ADVICE FROM EMPLOYEE PLANS RULINGS AND AGREEMENTS?
235
.01 Legislation authorizing user fees
235
.02 Requests to which user fees apply
…
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 RulingsMay 20, 1976related by meaning
tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty.
OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…
Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 2, 2024
… May schedule a pre-submission conference
234
.08 May schedule a conference to be held by telephone
235
SECTION 29. WHAT EFFECT WILL A LETTER RULING HAVE?
235
.01 Has same effect as a determination letter
235
.02 Will not apply to another taxpayer
235
.03 Will be used by the Service in examining the taxpayer’s return
2…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
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 RulingsFeb 28, 2024
…iod had expired on the date the notice of deficiency was sent.
Cf. Commissioner v. Lundy , 516 U.S. 235, 244 (1996) (“In most cases,
the notice of deficiency must be mailed within three years from the date
the tax return is filed.” (first citing I.R.C. §§ 6501(a), 6503(a)(1); and
then citing B adaracco v. Commissioner,…
IRCCourt RulingsJul 3, 1974related by meaning
ilar to the enumerated plans and that it therefore should not be treated in accordance with section 404 (a) but rather in accordance with section 162. Although a literal interpretation of the first sentence of section 404(a) would appear to support the position of respondent, we are not confined to such a literal readi…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…available to the agency" (quoting Skidmore v . Swift
& Co . , 323 U .S . 134, 139 (1944)) ; id . at 235 (concluding that a
tariff classification ruling by the U .S . Customs Service "may
surely claim the merit of its writer's thoroughness, logic, and
expertness, its fit with prior interpretations, and any other
sources…
IRCCourt RulingsJun 30, 1982related by meaning
ance standard of section 162(a)(1). Bianchi v. Comm issioner, 66 T.C. 324, 329-330 (1976), affd. without published opinion 553 F.2d 93 (2d Cir. 1977). Respondent contends that in order for a contribution to a pension plan to be deductible under section 404, the contribution must represent compensation for personal serv…
IRCCourt RulingsAug 26, 1963related by meaning
422, 441.
Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …