IRCCourt RulingsJun 4, 2014related by meaning
ication of a
pending or planned examination or investigation as a result of information
provided by the whistleblower. IRM pt. 25.2.2 (June 18, 2010). Additionally, the Tax Court has exclusive jurisdiction over appeals of award
determinations where a whistleblower provided information both before and after
the effectiv…
T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr… IRCTreasury DecisionsDec 9, 2013related by meaning
of safe harbor matching contributions for plan years beginning on or after January 1, 2015.
EMPLOYMENT TAX
T.D. 9646 T.D. 9646
REG–146620–13T.D. 9646 Temporary and proposed regulations under section 3402(p)(3) relating to voluntary withholding agreements allow the Secretary to issue guidance in the Internal Revenue Bu…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…
Notice 2024-86 — Extension of Certain Timeframes for Employee Benefit Plans, Participants, Beneficiaries, Qualified Beneficiaries, and Claimants Affected by Hurricane Helene, T… IRCNoticesDec 23, 2024
…which individuals may file a benefit claim under the plan’s claims procedure pursuant to 45 CFR 147.136(b) (incorporating 29 CFR 2560.503–1); (6) the date within which claimants may file an appeal of an adverse benefit determination under the plan’s claims procedure pursuant to 45 CFR 147.136(b) (incorporating 29 CFR 2…
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to 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…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
T.D. 9332 T.D. 9332 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…
IRCRegulationsMay 18, 2016
…uals $164,000; (2) two percent of $1,400,000 equals $28,000; and (3) $164,000 minus $28,000 equals $136,000. Thus, because $136,000 exceeds $100,000, the minimum net worth necessary for Trustee X to accept new accounts for 1996 is $136,000.(d) For 1996, the amount determined under § 1.408-2(e)(5)(ii)(C) for Trustee X i…
T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua… IRCTreasury DecisionsMar 7, 2016related by meaning
or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security.
T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
IRCPrivate Letter RulingsMar 10, 2006related by meaning
ration of the taxing statutes. If a ruling is
revoked or modified, the revocation or modification applies to all open years under the
TAM-134113-05
15 statutes, unless the Commissioner or his delegate exercises the discretionary authority
under § 7805(b) to limit the retroactive effect of the revocation or modification…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
136 T.C. No. 6 — Michael P. Schwab & Kathryn J. Kleinman v. Commissioner IRCCourt RulingsFeb 7, 2011
$136,000 a year; for -
Kleinman, it was $120,000. In some of the-ilslustrations that the
insurance company used, Angels & Cowboys would be paying such premiums for decades; in some, the firm would make pay premiums ,
for only ten years. But we find that the firm paid the premiums
only for the policies' first year.5 The…
IRCCourt RulingsAug 6, 1996related by meaning
by section 404(a)(6), and are therefore not deductible
in that year.
To reflect the foregoing and issues previously resolved,
Decision will be entered under Rule 155
.
T.D. 10001 — These regulations provide guidance related to section 401 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), enacted on Dec… IRCTreasury DecisionsAug 12, 2024related by meaning
isted transactions would be required to file disclosures with the IRS and would be subject to penalties for failure to disclose.
T.D. 10004, page 489. This document contains final regulations regarding the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizat…
IRCCourt RulingsJun 4, 2014related by meaning
tates that action by the IRS includes the modification of a pending or
planned examination or investigation as a result of information provided by the whistleblower. IRM pt. 25.2.2 (June 18, 2010).
Additionally, the Tax Court has exclusive jurisdiction over appeals of award
determinations where a whistleblower provided…
IRCCourt RulingsJan 26, 1984related by meaning
ing the amounts contributed by the employee shall be considered a gain from the sale or exchange of a capital asset held for more than 6 months. * * * Sec. 402(b) refers to the rules of sec. 83 for taxation of contributions. Sec. 83 generally provides that the time of inclusion would be when the employee’s rights are n…
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
76 FR 37208 — Group Health Plans and Health Insurance Issuers: Rules Relating to Internal Claims and Appeals and External Review Processes IRCFinal Rules (FR)Jun 24, 2011
…d 26 CFR 54.9812-1T, ERISA section 712 and 29 CFR 2590.712, and PHS Act section 2726 and 45 CFR 146.136.
Back to Citation
35.
See 26 CFR 54.9815-2719T(d)(2)(iv), 29 CFR 2590.715-2719(d)(2)(iv), and 45 CFR 147.136(d)(2)(iv).
Back to Citation
36.
See 26 CFR 54.9815-2719T(c)(2)(xi), 29 CFR 2590.715-2719(c)(2)(xi), and 4…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
89 FR 32346 — Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
this provision undermines the careful balance of labor relations in this country and argued that it is preempted by the National Labor Relations Act. After consideration of the comments, the Department has deleted the proposed recordkeeping requirements applicable to Section VII of PTE 86-128. However, as with PTE 202…