IRCCourt RulingsFeb 9, 2023★ strong match
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsMar 5, 2018related by meaning
¹² The Commissioner here also doesn't seek to redetermine income tax, but
only because the statute of limitations has run--he says if it hadn't, he'd redetermine the income tax too. We previously decided this was enough of a
distinction from Hellweg to let these cases go forward on the excise-tax issue
alone. Mazzei v…
IRCCourt RulingsApr 11, 2012★ strong match
…ave a conflict of interest"), aff'g T.C. Memo. 2004-269,
Van Scoten v. Commissioner, 439 F.3d 1243, 1253 (10th Cir. 2006) ("To be
reasonable, the professional adviser cannot be directly affiliated with the
promoter; instead, he must be more independent"), aff'g T.C. Memo. 2004-275,
Barlow v. Commissioner, 301 F.3d 714,…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsNov 17, 2016related by meaning
etitioner neglected to apply the correct method to reduce the maximum
benefits under section 415(b)(2)(C) for a retirement age before age 62 under its plan, where the plan did not provide for forfeiture of the participant's benefits at
death. By virtue of this error, portions of petitioner's contributions to the plan
d…
IRCCourt RulingsFeb 4, 1998
… failure was due to reasonable
cause and not willful neglect. See Kotmair v. Commissioner
,
86 T.C. 1253, 1263 (1986). A failure to file timely is due to
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…
IRCCourt RulingsDec 2, 2013
… the issues remaining for decision are:
(1) Whether petitioners are liable for tax on income of $33,1253 received
from the surrender of a life insurance contract. We hold that they are; and
i Unless otherwise indicated, all subsequent section references are to the
Internal Revenue Code (Code) in effect for the year in …
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 RulingsFeb 22, 1999related by meaning
112 T.C. No. 6
UNITED STATES TAX COURT
GIDEON L. MEDINA AND CORAZON P. MEDINA, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18999-97. Filed February 22, 1999.
H and W, who were both disqualified persons within
the meaning of sec. 4975, I.R.C., borrowed $340,000
from the qualified pension plan…
PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans IRCPrivate Letter RulingsAug 8, 2014related by meaning
arding
enforceable claims of the parties; and (ii) the parties'
assessments
of the relative strengths of their positions. We further conclude that the final settlement agreement approved by Court Order is within the range of reasonable
outcomes under the governing instruments and applicable State law.
Therefore, based …
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
…ge barriers and resource utilization in a pediatric emergency department. Pediatrics. 1999; 103(6): 1253-1256; Dewalt D.A., et al. Literacy and health outcomes: A systematic review of the literature. J. Gen Intern Med. 2004;19(12):1228-1239. doi:10.1111/j.1525-1497.2004.40153.x.
Back to Citation
84.
Id.
Back to Citati…
IRCCourt RulingsMay 27, 2004related by meaning
is liable for the
second-tier excise tax under section 4975(b). We note, however,
- 19 -
that sections 4961(a) and 4963(e)(1) generally allow for the abatement of a second-tier excise tax if the prohibited
transaction giving rise thereto is corrected within 90 days after
our decision sustaining the tax becomes final. …
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…
IRCPrivate Letter RulingsDec 2, 2005related by meaning
- -
- - -
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
IRCPrivate Letter RulingsSep 14, 2007related by meaning
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007related by meaning
3 (1978). See also H.R. Conf. Rep. No. 1800, 95th Cong., 2d Sess. 206 (1978).
The legislative history to the 1984 amendments to section 125 continues: The cafeteria plan rules of the Code provide that a participant in a nondiscriminatory cafeteria plan will not be treated as having received a taxable benefit offered un…
IRCCourt RulingsJan 14, 2013related by meaning
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…