IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026
… procurement procedures. For the May 2026 to February 2027 testing period, the contractor’s fee is $251 for each part of the EA SEE.
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCCourt RulingsMar 7, 2019
…can claim depreciation
deductions only for property it owns, Arevalo v. Commissioner, 124 T.C. 244,
251-52 (2005), aff d, 469 F.3d 436 (5th Cir. 2006), and can start depreciating
property only when it first places the property into service in its trade or business,
sec. 1.167(a)-10(b), Income Tax Regs. To prove entitle…
IRCProposed Rules (FR)Proposed Dec 23, 2025
… under NAICS code 621491 (HMO Medical Centers), which has a size standard of $44.5 million or less.[251]
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
IRCCourt RulingsOct 25, 2006
…eral tax purposes . See secs . 401(a) ,
(k) (1) , 4974 (c) (1) .
- 3 -
The other distribution, $116,251 .20, comprised the employer
and pretax employee contributions to petitioner's 401(k) ; income
tax was withheld from this distribution, and he used a portion of
the distribution to pay off personal debts . He used th …
IRCCourt RulingsJan 14, 2013★ strong match
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…
IRCCourt RulingsNov 17, 2016
…he statute
had been amended to increase the age to 62.
- 27 -
Rev. Rul. 98-1, Q&A-7, 1998-1 C.B. at 251. Put another way, "in determining
actuarial equivalence for this purpose, it is generally necessary to use a reasonable
mortality table. However, the mortality decrement may be ignored to the extent
that a forfeiture…
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
…letters on § 403(b) pre-approved plans pursuant to Rev. Proc. 2021-37
250
.07 Determination letters
251
.08 Opinion letters on § 403(b) prototype plans pursuant to Rev. Proc. 2013-22 and Rev. Proc. 2014-28
251
.09 Advisory letters on § 403(b) VS plans pursuant to Rev. Proc. 2013-22 and Rev. Proc. 2014-28
251
.10 User f…
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 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…
Notice 2020-61 — Special Funding and Benefit Limitation Rules for Single-Employer Defined Benefit Pension Plans under the CARES Act IRCNoticesAug 24, 2020
… The portion of the June 1 contribution that is used to satisfy the first quarterly installment is $251,771 ($250,000 × 1.0565(47/366) = $251,771). Therefore, the balance of that contribution, which will be applied to the second quarterly installment, is $148,229 ($400,000 - $251,771 = $148,229). The remaining contribu…
IRCCourt RulingsMay 27, 1968related by meaning
404(a) (3). See Armanco Productions, Inc., 49 T.C. 114 (1967). Pursuant to the stipulation, this conclusion will decide the issues in the other cases. Decisions will be entered under Rude 60.
All Code references herein are to the Internal Revenue Code of 1954.
Petitioner points to Rev. Rul. 66—12, 1966— 1 C.B. 72, wher…
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 16, 2015
…2002); sec. 1.6664-4(b)(1), Income Tax Regs.; cf United States v. Boyle, 469 - 31 -
[*31] U.S. 241, 251 (1985). A taxpayer may rely on the advice of any tax adviser,
lawyer, or accountant. See Boyle, 469 U.S. at 251. Reliance on a professional tax
adviser will not be considered reasonable, however, if the adviser is a …
IRCCourt RulingsMar 16, 2015related by meaning
report the initial retirement distribution of $4,984 from State Street;
that his aggregate retirement distribution of $211,499 was includible in gross income; that he was liable under section 72(t) for additional tax equal to 10% of
the retirement distribution includible in gross income; and that he was liable for an
a…
Rev. Rul. 2014-24 — This revenue ruling modifies the list of group trust retiree benefit plans eligible to participate in 81–100 group trusts in accordance with the requirements o… IRCRevenue RulingsSep 8, 2014
…ipate in 81–100 group trusts in accordance with the requirements of Rev. Rul. 2011–1, 2011–2 I.R.B. 251, as modified by Notice 2012–6, 2012–3 I.R.B. 293, to include trusts of certain retirement plans qualified only under the Puerto Rico Code (Código de Rentas Internas para un Nuevo Puerto Rico de la Ley Núm. 1 de 31 de…
Notice 2012-6 — This notice extends and expands the transition relief provided under Rev. Rul. 2011-1, 2011-2 I.R.B. 251, and Rev. Rul. 2008-40, 2008-2 C.B. 166, for certain g… IRCNoticesJan 17, 2012
…his notice extends and expands the transition relief provided under Rev. Rul. 2011-1, 2011-2 I.R.B. 251, and Rev. Rul. 2008-40, 2008-2 C.B. 166, for certain group trusts, certain retirement trusts that qualify under the Puerto Rico Internal Revenue Code (Puerto Rico Code) and that participate in group trusts, and certa…