IRCCourt RulingsMay 22, 1996
…in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1996-231
UNITED STATES TAX COURT
CHARLES E. KING, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18362-93. Filed May 22, 1996.
Charles E. King, pro se.
Reginald R. Corlew
, for respondent.
MEMORANDUM O…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsNov 5, 1999
…cy $188,983
Employer's normal cost for plan
year as of 11/1/88 25,643 Interest 17,170
Total charges 231,796
Credits to funding standard account: -0-
Funding deficiency 231,796
reports that the employer owes $231,796 in contributions to the
plan which are more than 3 months overdue.
The Schedule B
4
of Form 5500 for the…
IRCCourt RulingsDec 18, 2012
…ated;
3. whether petitioners' gross income for the subject years includes interest
income of $480, $231, $148, $798, $593, and $653, respectively. We hold that it
does;
4. whether petitioners' gross income for the subject years includes
"unreported income" of $11,122, $22,520, $8,502, $155,523, $110,720, and
$88,965, r…
IRCCourt RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…could lead higher-cost providers to face new pressure to lower costs, potentially decreasing costs.[231]
IRCCourt RulingsJul 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
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
ed
231
.10 Extension of 30-day or 21-day period may be granted if justified
231
.11 Case closed if taxpayer does not submit additional information
231 .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…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to
the Tax Court Rules of Practice and Procedure.
the parties' cross-motions for partial summary judgment. …
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
… REQUESTS
SECTION 27. HOW DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HANDLE LETTER RULING REQUESTS?
231
.01 In general
231
.02 Is not bound by informal opinion expressed
231
.03 Will return any letter ruling request mistakenly sent to wrong address
231
.04 Tells taxpayer if request lacks essential information during in…
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 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…
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
…additional conferences
230
.06 Requires written confirmation of information presented at conference
231
.07 May schedule a pre-submission conference
231
.08 May schedule a conference to be held by telephone
231
SECTION 29. WHAT EFFECT WILL A LETTER RULING HAVE?
231
.01 Has same effect as a determination letter
231
.02 …
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…
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
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
…ed guidance
230
.05 Issues in prior return
230
.06 Generally not to business associations or groups
231
.07 Generally not to foreign governments
231
.08 Generally not on federal tax consequences of proposed legislation
231
SECTION 25. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HAVE DISCRETION T…
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…
Rev. Proc. 2016-6 — Revised procedures are provided for issuing determination letters on the qualified status of employee plans under sections 401(a), 403(a), 409 and 4975 of the … IRCRevenue ProceduresJan 4, 2016
…03 Determination letter based solely on administrative record
230
.04 Notice of final determination
231
.05 Issuance of the notice of final determination
231
SECTION 20. EXHAUSTION OF ADMINISTRATIVE REMEDIES
231
.01 In general
231
.02 Steps for exhausting administrative remedies
231
.03 Applicant’s request for § 7805(b…
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
…01 Schedules a conference if requested by taxpayer
230
.02 Permits taxpayer one conference of right
231
.03 Disallows verbatim recording of conferences
231
.04 Makes tentative recommendations on substantive issues
231
.05 May offer additional conferences
231
.06 Requires written confirmation of information presented at…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …