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88 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 1.501(h)-3(d) — Lobbying or grass roots expenditures normally in excess of ceiling amount.
    IRCRegulationsJul 12, 2016
    …d)(1) (1) Time of application. An organization that is denied exemption from taxation under section 501(a) by reason of section 501(h) and this section may apply on Form 1023 for recognition of exemption as an organization described in section 501(c)(3) for any taxable year following the first taxable year for which ex…
  2. IRCRegulationsJul 12, 2016
    (c)(4) (4) Under section 501(c)(17)(B)(iii), a plan is not considered discriminatory merely because the plan provides benefits only for employees who are not eligible to receive benefits under another plan which satisfies the requirements of section 501(c)(17)(A) and which is funded solely by contributions of the emplo…
  3. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984
    …integral part of a local government, it could not meet the requirements for exemption under section 501(cX3) of the Code. "On the other hand a wholly-owned state or municipal instrumentality which is a counterpart of an organization described in section 501(c)(3) of the Code such as a separately organized school, colle…
  4. Treas. Reg. § 1.501(r)-2(a) — Failures to satisfy section 501(r).
    IRCRegulationsJul 12, 2016
    (a) (a) Revocation of section 501(c)(3) status. Except as otherwise provided in paragraphs (b) and (c) of this section, a hospital organization failing to meet one or more of the requirements of section 501(r) separately with respect to one or more hospital facilities it operates may have its section 501(c)(3) status r…
  5. 81 T.C. 735; 81 T.C. No. 44 — Bricklayers Ben. Plans, Inc. v. Commissioner
    IRCCourt RulingsOct 13, 1983
    arly fall outside the coverage of sec. 501(c)(9). However, respondent does not raise this argument and, thus, it is unnecessary for us to consider it. Petitioner alternatively argues that if it is reasonable to exclude pension benefits under sec. 501(c)(9), then sec. 1.501(c)(9)-3(e), Income Tax Regs., which permits va…
  6. Treas. Reg. § 1.501(e)-1(d) — Cooperative hospital service organizations.
    IRCRegulationsJul 12, 2016
    (d) (d) Patron-hospitals (d)(1) (1) Defined. Section 501(e) only applies if the organization performs its services solely for two or more patron-hospitals each of which is— (d)(1)(i) (i) An organization described in section 501(c)(3) which is exempt from taxation under section 501(a), (d)(1)(ii) (ii) A constituent part…
  7. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012
    …rganization exempt from tax under subtitle A. We also disagree with respondent's reading of section 501(b). Respondent would like us to ignore the plain language of section 501(b), which provides that a section 501(c)(3) organization shall be subject to tax to the extent it has UBTI but, notwithstanding any unrelated b…
  8. Treas. Reg. § 1.501(c)(3)-1(f) — Organizations organized and operated for religious, charitable, scientific, testing for public safety, literary, or educational purposes, or for the prevention…
    IRCRegulationsJun 30, 2017
    …1) (1) Application process. An organization that applies for recognition of exemption under section 501(a) as an organization described in section 501(c)(3) must establish its eligibility under this section. The Commissioner may deny an application for exemption for failure to establish any of section 501(c)(3)'s requi…
  9. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. 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…
  10. Treas. Reg. § 1.501(h)-1(a) — Application of the expenditure test to expenditures to influence legislation; introduction.
    IRCRegulationsJul 12, 2016
    …re are certain requirements an organization must meet in order to be a charity described in section 501(c)(3). Among other things, section 501(c)(3) states that “no substantial part of the activities of [a charity may consist of] carrying on propaganda, or otherwise attempting to influence legislation, (except as other…
  11. Treas. Reg. § 1.501(c)(4)-1(a)(2)(ii) — Civic organizations and local associations of employees.
    IRCRegulationsJul 12, 2016
    …al public in a manner similar to organizations which are operated for profit. See, however, section 501(c)(6) and § 1.501(c)(6)-1, relating to business leagues and similar organizations. A social welfare organization that is not, at any time after October 4, 1976, exempt from taxation as an organization described in se…
  12. Treas. Reg. § 1.501(h)-2(b) — Electing the expenditure test.
    IRCRegulationsJul 12, 2016
    …Organizations eligible to elect the expenditure test (b)(1) (1) In general. For purposes of section 501(h) and the regulations thereunder, an organization is an eligible organization for a taxable year if, for that taxable year, it is— (b)(1)(i) (i) Described in section 501(c)(3) (determined, in any year for which an e…
  13. Treas. Reg. § 1.501(r)-0 — Outline of regulations.
    IRCRegulationsJul 12, 2016
    This section lists the table of contents for §§ 1.501(r)-1 through 1.501(r)-7. § 1.501(r)-1 Definitions.(a) Application.(b) Definitions.(1) Amounts generally billed (AGB).(2) AGB percentage.(3) Application period.(4) Authorized body of a hospital facility.(5) Billing and collections policy.(6) Date provided.(7) Dischar…
  14. 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…
  15. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  16. 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…
  17. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  18. 97 T.C. 385; 97 T.C. No. 27 — Zabolotny v. Commissioner
    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…
  19. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
  20. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…