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83 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999★ strong match
    1 Unless otherwise indicated, all section references are to (continued...) T.C. Memo. 1999-199 UNITED STATES TAX COURT DON LAVERNE CLARKE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 151-97. Filed June 18, 1999. Don Laverne Clarke, pro se. Anthony Hoefer , for respondent. MEMORANDUM FINDINGS …
  2. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005★ strong match
    ments, as in effect in 2001. Article 18(2)(a) of the 1994 U.S./French Tax Convention provides that contributions to a French retirement plan generally are treated in computing U.S. tax as though they were paid to a pension or other retirement arrangement established and recognized for tax purposes in the United States …
  3. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    3 in p articular s erve what is principally a regulatory functio n —persuading public charities, private foundations, employee trusts, and other tax - fa vored plan s to comply with the requirement s Congress has ordaine d for continued tax-exempt status. Section 4973 imposes a 6% exaction on the amount of an excess co…
  4. T.C. Summary Opinion 2007-180 — Suzanne E. Barrera, a.k.a. Suzanne E. Battle v. Commissioner
    IRCCourt RulingsOct 24, 2007
    … requests for money, and there was always money available whenever petitioner requested it. In June 1996, petitioner and Mr. Barrera timely filed (under extension) their joint return for taxable year 1995. The 1995 joint return reported adjusted gross income of $199,170, and tax due of $42,149, which amount was paid by…
  5. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    tions in his gross income for 1995. The only exception to section 408(d)(1) that might apply in the present case is section 408(d)(6), which provides: (6) Transfer of account incident to divorce.--The transfer of an individual's interest in an individual retirement account or an individual retirement annuity to his spo…
  6. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    ) and (b) of section 4975. Section 4975 was added to the Internal Revenue Code by title II of ERISA. ERISA sec. 2003(a), 88 Stat. 971. Section 4975(a) and (b) imposes a two-tier excise tax on prohibited transactions. The policy behind the enactment of section 4975 was to tax disqualified persons who engage in self-deal…
  7. 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 …
  8. 115 T.C. No. 19 — Flahertys Arden Bowl, Inc. v. Commissioner
    IRCCourt RulingsSep 25, 2000related by meaning
    provisions” including section 4975. The tax provisions, contained in the Internal - 6 - Revenue Code, provide the statutory framework for the tax laws governing employee benefit plans and generally are administered by the Department of the Treasury. See Rutland v. Commissioner , 89 T.C. 1137, 1143 n.4 (1987). There are…
  9. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …er Strategies is entitled to business expense deductions for meals and entertainment expenses of $2,199 and $4,739 for 2004 and 2005, respectively, and travel expenses of $53,707 for 2005; (4) whether petitioner is liable for additions to tax under section 6651(a)(1) for failure to file Forms 5329, Additional Taxes on …
  10. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …ed guidance 198 .05 Issues in prior return 198 .06 Generally not to business associations or groups 199 .07 Generally not to foreign governments 199 .08 Generally not on federal tax consequences of proposed legislation 199 SECTION 25. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HAVE THE DISCRETI…
  11. 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, 2024
    …1-1(a)(1) and (2) as to who is the owner of a qualified film or television production. (42) Section 199.—Income Attributable to Domestic Production Activities.—The determination under § 1.199-3(f)(1) as to who is the taxpayer that has the benefits and burdens of ownership under Federal income tax principles of any qual…
  12. Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Dec 30, 2024
    …e a copy of plan and amendments 198 .04 Restatements required 198 .05 Section 414(x) combined plans 199 SECTION 12. WHEN MAY AN ADOPTER OF A PRE-APPROVED PLAN (STANDARDIZED OR NONSTANDARDIZED) SUBMIT A DETERMINATION LETTER APPLICATION? 199 .01 Eligibility to apply for a determination letter for a Cycle 3 qualified pre-…
  13. 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…
  14. Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t…
    IRCRevenue ProceduresSuperseded Jan 4, 2021
    …03 Determination letter applications on Form 5300 196 .04 Scope of review 198 .05 Submission period 199 .06 Reliance equivalent to determination letter 199 SECTION 13. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR FORM 5307? 199 .01 Scope 199 .02 Form 5307 filing procedures 199 .03 Additional information with…
  15. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …f subsequent publication of revenue ruling, etc. 198 .04 Effect of subsequent amendment by employer 199 .05 Revocation or modification of a determination letter 199 .06 Determination letter revoked or modified based on material change in facts applied retroactively 199 .07 Not otherwise generally revoked or modified re…
  16. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    rty within the 10-year period ending on the date of the transfer. (4) Amount involved.--The term "amount involved" means, with respect to a prohibited transaction, the greater of the amount of money and the fair market value of the other property given or the amount of money and the fair market value of the other prope…
  17. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    …ng determination letters 198 .02 Forms 198 .03 Application must include copy of plan and amendments 199 .04 Restatements required 199
  18. 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
    …hority must be distinguished 198 .10 Employer-employee relationship 198 .11 Incomplete applications 199 .12 Effect of failure to disclose material fact 199 .13 Where to file requests 199 .14 Submission of related plans 200 .15 Withdrawal of requests 200 .16 Right to status conference 200 .17 How to request status confe…
  19. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
    IRCCourt RulingsJun 1, 1987related by meaning
    significance save that the words are strung together with syntactical correctness. * * * [Hand, “Thomas Walter Swan,” 57 Yale L. J. 167, 169 (1947).] Section 4975, as added to the Internal Revenue Code by title II of ERISA, Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, imposes two levels of excise tax on a prohibited …
  20. Treas. Reg. § 1.430(a)-1(g) — Determination of minimum required contribution.
    IRCRegulationsSep 9, 2016
    …t value of the remaining three waiver amortization installments with respect to the 2014 waiver is $199,242, which is determined using the first segment rate of 5.50%.(iii) As of January 1, 2017, the present value of the remaining five waiver amortization installments with respect to the 2016 waiver is $182,701, which …