REG-106796-12 — These proposed regulations provide guidance on the application of section 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for serv… IRCProposed Rules (FR)Proposed May 28, 2013
y 1, 2026, is $197,449. Therefore, the remuneration attributable to services performed by K in J’s 2021 taxable year is $50,537 ($197,449 - $146,911). (viii) As of December 31, 2022, K has a right to a $297,500 payment on January 1, 2026 ($425,000 x 10% x 7 years of service). The present value as of December 31, 2022, …
IRCCourt RulingsJun 18, 1959
….43
Taxes. 1,074.34 2,140.98
Contributions. 206.00
Depreciation. 73.61 515.70
Depletion. 119,689.38 131,494.22
Other deductions. 5,385.15 11,026.00
Total deductions. (133,370.64) (161,352.83)
Net income.-120,210.13 131,494.22
Depletion computation:
Total production (sales) 1,714,327.10 1,935,793.57
Share of profits (46…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsFeb 19, 2020
…. The notice disallows petitioner's deduction for
"unidentified expenses" of $278,933 for 2012 and $131,947 for 2013. The notice
states that the unidentified expenses were disallowed because respondent "could
not verify whether these Unidentified Expenses were (a) ordinary and necessary to
82 FR 47792 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…
In general. Beginning at the time described in paragraph (b) of this section and subject to §§ 147.131 and 147.132, a group health plan, or a health insurance issuer offering group or individual health insurance coverage, must provide coverage for and must not impose any cost-sharing requirements (such as a copayment,…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…for or supported to the extent they exceed the exemptions and accommodation set forth in 45 CFR 147.131 and 147.132. Previous versions of the regulation placed that limit in 45 CFR 147.130(a)(1), but did not reiterate it in § 147.130(a)(1)(iv). To clearly set forth the applicability of the exemptions and accommodation,…
82 FR 47838 — Moral Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Oct 13, 2017
…her amended in paragraphs (a)(1) introductory text and (a)(1)(iv) by removing the reference “§§ 147.131 and 147.132” and adding in its place the reference “§§ 147.131, 147.132, and 147.133”.
§ 147.131
[Amended]
8. Section 147.131, as revised elsewhere in this issue of the Federal Register
, is further amended—
a. In pa…
IRCRegulationsSep 9, 2016
…ed to January 1, 2010, using the effective interest rate for 2010. This amount is calculated as $24,197 ($25,528 ÷ 1.055).(iv) The prefunding balance as of January 1, 2011, is reduced by the deemed election of $15,000 and the discounted amount used to offset the 2010 minimum required contribution ($24,197), and adjuste…
IRCCourt RulingsApr 12, 1979related by meaning
…able year.
We note that this case is not governed by the Employee Retirement Income Security Act of 1974, Pub. L. 93-406, 88 Stat. 829, and we express no opinion as to whether a different result should be reached for subsequent years in light of the provisions of that act.
Decision will be entered under Rule 155.
All r…
IRCCourt RulingsJun 9, 2009
…ntitled a full deduction in 2004 for those payments . Customer
lists are generally considered sec . 197 intangibles that must be
amortized over a 15-year' period . Sec" . 197(a), (d) (1) (C) (ii) ;
sec . 1 .197-2(b)(4), income Tax Regs .
21 -
2004, and we sustain respondent's dete mination disallowinglth e
deduction .
…
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 RulingsJul 25, 1974related by meaning
tion of the trust, petitioner’s recourse is to have the trust accounting records set straight and to receive the 1967 trust income rightfully due her. The fourth issue involves an addition to tax under section 6653(a) . The determination of the respondent in this regard is prima facie correct and petitioner has the bur…
PBGCPBGC Opinion LettersJul 8, 1996
…ber
22, 1981 ),
No. 81-30 (S eptember 22, 19 81),
No. 81-13 ( May 13, 1981) , No. 79- 6 (Apri l 10, 1979), No. 78-
25 ( Oc tobe r 31 , 197 8), N o. 77 -152 (July 13 , 197 7), an d N o. 76 -95 (A ugust 2 , 197 6).
The
[*6] Depart ment of Labor and the I RS have consider ed simi lar
factors
in i nter pret ing sect ion 3(…
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
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
PBGCPBGC Opinion LettersJul 8, 1996
…8 1) , P BGC Opi ni on Let te r 8 1- 13 ( May 13, 198 1) , P BGC
Op inion L etter 79 -6
(Apri l 10,
1979),
PBGC
Op in io n L et te r 7 8- 25 ( Oct obe r 3 1, 197 8) , P BGC Opi ni on Let te r 7 7- 152 (J ul y 1 3, 197 7) an d PBGC
Op inion L etter 76 -95 (A ugust 2 , 197 6).
The
Depart ment of Labor
("DO L") and the In…
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…
IRCCourt RulingsJul 30, 1985related by meaning
…cuit; this case would be appealable to the Ninth Circuit. Golsen v. Commissioner, 54 T.C. 742, 751 (1970), affd. 445 F.2d 985 (10th Cir. 1971), cert. denied 404 U.S. 940 (1971).
We have followed this approach in many cases. E.g., Van Sant v. Commissioner, T.C. Memo. 1984-535; Craine v. Commissioner, T.C. Memo. 1984-513…
IRCCourt RulingsMay 22, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year 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…
IRCCourt RulingsJul 5, 1983related by meaning
so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…