IRCCourt RulingsNov 30, 2006
… the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979-04S. Filed November 30, 2006.
William Edward and Patricia Marie Colom…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…ficiaries, and enrollees seeking pricing information by phone. This results in a one-time burden of 184 hours per issuer or TPA, with an estimated associated cost of $8,688. As shown in Table 10, for all 1,580 issuers and TPAs, the total estimated one-time training hour burden would be 290,720 hours, with a correspondi…
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…
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020
ers
183
.02 Forms
183
.03 Application must include copy of plan and amendments
184
.04 Restatements required
184
.05 Section 414(x) combined plans
184 SECTION 12A. WHEN MAY AN ADOPTER OF A MASTER AND PROTOTYPE OR VOLUME SUBMITTER PLAN SUBMIT A DETERMINATION LETTER APPLICATION?
184
.01 Eligibility to apply for a determi…
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019
mpliance with Title IV of ERISA
184
.05 Termination prior to time for amending for change in law
184
.06 Restatement not required for terminating plan 184
SECTION 16. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR GROUP TRUSTS?
184
.01 Scope
184
.02 Required information
185
.03 Forms
185
SECTION 17. WHAT ARE T…
IRCProposed Rules (FR)Proposed May 13, 2026
…ximately 65 out of 373 health insurance companies had total premium revenue of $47 million or less.[184]
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
…t must request letter for plan in the name of the controlling member
183
.03 Where to file requests
184
.04 Addition of employers
184
SECTION 15. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINATION UPON TERMINATION OR DISCONTINUANCE OF CONTRIBUTIONS, NOTICE OF MERGER, CONSOLIDATION, ETC?
184
.01 Scope
184
…
IRCCourt RulingsMay 3, 1995
Cumulative Difference
-0-4,184,771 1,856,154 3,504,159 680,612 CD OO <Ji
1,025,021 5,209,792 1,705,633 5,209,792 -0-CD OO <3
Total 5,209,792 5,209,792 Petitioner’s payment to the National Presto VEBA during the 1986 taxable year in the amount of $1,856,154 relates solely to amounts that petitioner had previously deduct…
IRCPrivate Letter RulingsDec 1, 2006
…mount of claims against the estate under section
2053(a). See Estate of Davenport v. Commissioner
, 184 F.3d 1176 (10
th
C ir. 1999);
Richardson v. Commissioner
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
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…
IRCCourt RulingsSep 30, 1991related by meaning
o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
IRCCourt RulingsJun 17, 1997
…ll Suspense Account activity through
October 31, 1994:
- 35 -
Total Out
Total In
Accounting fees $4,184 ---
Actuarial gains --- $252,977
Administrative fees 192,000 ---
Death benefit 3,398 ---
Death forfeitures --- 474,839
Expense allocations 22,939 ---
Interest earned --- 48,581
Legal fees 387,990 256
Miscellaneous 2,…
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
…73
.03 Additional information required in certain circumstances
182
.04 Address to send the request
184
.05 Pending letter ruling requests
184
.06 When to attach letter ruling to return
184
.07 How to check on status of request
184
SECTION 7. WHAT ACTIONS ARE TAKEN IF A REQUEST IS WITHDRAWN OR EMPLOYEE PLANS RULINGS AN…
IRCCourt RulingsAug 10, 2015related by meaning
mmissioner, 131 T.C. 185 (2008), supplementing T.C. Memo.
2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144.
- 12 -
II. Section 1839
A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and
necessary expenses incurred in conducting a trade or business or for the
production of income. Se…
Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par… IRCRevenue ProceduresModified Aug 2, 2021
… III. DEFINITIONS, CORRECTION PRINCIPLES, AND RULES OF GENERAL APPLICABILITY
SECTION 5. DEFINITIONS
184
.01 Definitions for Qualified Plans
184
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
…ON 18. WHAT ARE THE PROCEDURES FOR REQUESTING SECTION 401(h) and SECTION 420 DETERMINATION LETTERS?
184
.01 Scope
184
.02 Required information for § 401(h) determination
184
.03 Required information for § 420 determination
184
PART IIB. INTERESTED PARTY NOTICE AND COMMENT
SECTION 19. WHAT RIGHTS TO NOTICE AND COMMENT D…
IRCCourt RulingsOct 11, 1957related by meaning
s that its enforcement would amount to a deprivation of property without due process of law as required under the Fifth Amendment to the Constitution. We have carefully considered the decision of the Seventh Circuit in the Kohl case, and its application as a precedent in the problem which confronts us. With all due res…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.