IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
rom the proceeds of the life insurance contract. See generally Cadwell
v. Commissioner, 136 T.C. 38, 63-64 (2011), aff'd, 483 Fed. Appx. 847 (4th Cir. 2012). Section 1.61-22, Income Tax Regs., is effective for split-dollar life
insurance arrangements entered into after September 17, 2003, and an arrangement
that is "ma…
IRCProposed Rules (FR)Proposed May 13, 2026
…pted fertility benefits coverage, resulting in an estimated 743,361 individuals enrolling annually.[154]
The Departments acknowledge the uncertainty around this estimate of the number of individuals that would enroll and request comment on ways to improve it.
G. Requests for Comments
The Departments invite comments add…
IRCCourt RulingsJun 4, 1997related by meaning
amount is erroneously treated
as self-employment income, or if an amount is
erroneously treated as wages, and
(2) If the correction of the error would require an assessment of one such tax and the
refund or credit of the other tax, and
- 23 -
(3) If at any time the correction of the
error is authorized as to one such t…
IRCCourt RulingsMar 10, 2020
BD
154 T.C. No. 6
UNITED STATES TAX COURT
SANDRA M. CONARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27571-10. Filed March 10, 2020.
P received $61,777 in distributions from a qualified retirement
plan in 2008, when P was not yet 59-1/2 years old, was not disabled,
and was not eligible for …
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
IRCCourt RulingsMar 31, 1997related by meaning
1
All section references are to the Internal Revenue Code
as amended, unless otherwise indicated. All Rule references are
to the Tax Court Rules of Practice and Procedure.
T.C. Memo. 1997-159
UNITED STATES TAX COURT
ROBERT CHARLES FOHRMEISTER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11748…
IRCCourt RulingsApr 2, 2020
…Commissioner, T.C.
Memo. 1957-129, aff'd in part, rev'd in part, 266 F.2d 698 (9th Cir. 1959). It
- 154 -
[*154] seems that the Office of Appeals determined that the report (i.e., the May
2011 Form 4549) was not conclusive as to Goldberg's liability for interest.
The notice of determination briefly touched on Goldberg'…
IRCCourt RulingsJul 3, 1974related by meaning
ilar to the enumerated plans and that it therefore should not be treated in accordance with section 404 (a) but rather in accordance with section 162. Although a literal interpretation of the first sentence of section 404(a) would appear to support the position of respondent, we are not confined to such a literal readi…
IRCFinal Rules (FR)Oct 8, 2019
…rivate sector, of $100 million or more in any one year (adjusted annually for inflation, currently $154 million).[107]
As discussed in the OCC's Regulatory Flexibility Act section, the costs associated with the final rule, if any, would be
de minimis.
Therefore, the OCC concludes that the final rule will not result in …
IRCCourt RulingsOct 28, 1987
…sen v. Commissioner
Docket No. 4909-86
United States Tax Court
89 T.C. 939; 1987 U.S. Tax Ct. LEXIS 154; 89 T.C. No. 65;
October 28, 1987; As amended December 7, 1987 October 28, 1987, Filed
*154 Decision will be entered under Rule 155.
Decedent died testate on Apr. 20, 1982, survived by his wife and six children. His …
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 …
IRCProposed Rules (FR)Proposed Dec 23, 2025
…ice and for each plan, insurance policy, or coverage included in an aggregated Allowed Amount File.[154]
The Departments finalized this requirement in the 2020 final rules because if the threshold were applied to the aggregated claims data at the service provider level, rather than for each plan or coverage as is requi…
IRCCourt RulingsDec 18, 2012★ strong match
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
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
…O REVENUE PROCEDURE 2017–4?
153
.01 In general
153
.02 Changes related to pre-approved plan program
154
.03 Changes to fees for EP VCP Submissions
154
.04 Changes to other fees
155
.05 Other changes
155
PART I. GENERALLY APPLICABLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGRE…
IRCCourt RulingsNov 6, 1962related by meaning
ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated.
Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act.
Thls section was originally desi…
Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl… IRCRevenue RulingsMar 8, 2004
Rul. 66-110, as amplified by Rev. Rul. 67-154, for periods after December 31, 2003, with respect to arrangements entered into after January 28, 2002. Rev. Rul. 2003-105, 2003-40 I.R.B. 696, obsoleted Rev. Rul. 66-110 for arrangements entered into after September 17, 2003, except as provided in paragraph 3 of Section I…
IRCCourt RulingsSep 24, 2026
…
Examination Division ’ s determination to assert a penalty. See Belair
Woods, LLC v. Commissioner, 154 T.C. 1, 15 (2020) .
Petitioner does not dispute that the IRS met these requirements
here. The IRS secured managerial approval of the penalty on May 20 ,
202 4, when the revenue agent’s manager noted in the examinatio…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…e the vesting protections applicable to the
VTTM. See Concerned Dublin Citizens v. City of Dublin , 154 Cal. Rptr.
3d 682, 698 (Ct. App. 2013) (holding that new threshold requirements
for greenhouse gases were not new information requiring a
supplemental environmental impact report because the potential
environmental i…
IRCCourt RulingsAug 24, 1995related by meaning
section 1041. See Balding v. Commissioner, 98 T.C. 368 (1992).
In order to implement the views expressed herein,
An appropriate order will be issued. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules o…