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86 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 90 FR 3092 — Automatic Enrollment Requirements Under Section 414A
    IRCProposed Rules (FR)Proposed Jan 14, 2025
    …uirements for unenrolled participants set forth in section 414(bb), as added to the Code by section 320 of the SECURE 2.0 Act. The proposed amendments to § 1.414(w)-1 also would address section 402A(e)(5)(C) of the Code, which was added to the Code by section 127 of the SECURE 2.0 Act, as well as section 341 of the SEC…
  2. T.C. Memo. 2020-48 — Henry C. Williams & Sonja L. Johnson v. Commissioner
    IRCCourt RulingsApr 16, 2020
    …aspects of the business. On the basis of petitioner husband's credible testimony, we find that the $320,000 purchase price was wholly allocable to the insurance firm's workforce in place, information base, and goodwill, all of which are amortizable section 197 intangibles.¹² See sec. 197(c) and (d). However, the amorti…
  3. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    es, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C. 717, 759 (1971), where the taxpayers were denied the benefit of certain partnership losses allocable to corpus, because they were found to be the grantor-owners only to …
  4. 90 FR 60432 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Dec 23, 2025
    …incur a total one-time burden of 10,112 hours with an associated total cost of approximately $1,428,320. Under the high-end scenario, for all issuers and TPAs, the total one-time burden would be 50,560 hours with an associated total cost of approximately $7,141,600, as shown in Table 16. ( printed page 60476)
  5. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
  6. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    Yolanda) was the distributee (within the meaning of section 402(a)(1)) of the entire distribution here in dispute. II. Taxability of the Distribution Preliminarily, we note that the apparent effect of petitioner’s contention that section 72 authorizes him to exclude $75,000 from income — if we were to agree with it — …
  7. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  8. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019★ strong match
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  9. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …lan paid the first-year premium, and, at the end of that year, the conversion credit balance was $1,320.76 ($1,620 - $356.11 + $56.87); the $56.87 is the interest of 4.5 percent earned on the conversion credit balance (($1,320.76 - $56.87) x 4.5% = $56.87)). None of the conversion credit balance could have been transfe…
  10. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    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. …
  11. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020★ strong match
    …for deductibility under section 162 generally is a question of fact. See Commissioner v. Heininger, 320 U.S. 467, 475 (1943). An ordinary expense is one that commonly or frequently occurs in the taxpayer's business, Deputy v. du Pont, 308 U.S. 488, 495 (1940), and a necessary expense is one that is appropriate and help…
  12. 81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities
    IRCProposed Rules (FR)Proposed Apr 4, 2016
    …have an impact on what is proposed in this notice. Back to Citation 34.   See 31 CFR 1020.210, 1020.320, 1021.210, 1021.320, 1022.210, 1022.320, 1023.210, 1023.320, 1024.210, 1024.320, 1025.210, 1025.320, 1026.210, and 1026.320, respectively. Back to Citation 35.  31 CFR 1020.410(a) (recordkeeping requirements for bank…
  13. Treas. Reg. § 1.72-16(c)(3) — Life insurance contracts purchased under qualified employee plans.
    IRCRegulationsJul 26, 2016
    …01(d)(1)(B) is applicable to such $280. The remaining portion of each annual $3,000 installment, $1,320, is attributable to the cash value of the contract and is treated under section 72, as follows: Amount actually contributed by the employee 0 Amount considered contributed by employee by reason of section 101(b) $5,0…
  14. 85 FR 72158 — Transparency in Coverage
    IRCFinal Rules (FR)Nov 12, 2020
    ….00 594,880.00 Business Analyst 2,080 120.00 249,600.00 UX Researcher/Service Designer 2,080 154.00 320,320.00 Designer 1,560 116.00 180,960.00 DevOps Engineer 2,080 181.00 376,480.00 Web Database/Application Developer IV 3,120 152.00 Total per Respondent 24,440 3,446,320.00 Table 6B—Estimated Year Two Implemenation Co…
  15. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  16. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  17. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    …e is one that commonly or frequently occurs in the taxpayer’s business); Commissioner v. Heininger, 320 U.S. 467, 471 (1943) (explaining that a necessary expense is one that is appropriate and helpful in carrying on the taxpayer’s business) ; Treas. Reg. § 1.1621(a) . Generally, the performance of services as an employ…
  18. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …arrive at the gain realized on the California property. In particular, he calculated a total of $35,320 in depreciation as follows: 17 Year Amount of Depreciation 1985 $2,906 1986 13,374 1987 12,225 1988 6,364 1989 451 Total 35,320 Such figures would seem to indicate that petitioners did, in fact, rent out the Californ…
  19. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  20. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012
    …n expenditure is ordinary and necessary is generally a question of fact. Commissioner v: Heiningerg 320 U.S. 467, 475.(1943). Ah expense is ordinary if it is customary or usual within a particular trade, business, or industry or relates to a transaction "of - -33_ common or frequent occurrence in the type of business i…