T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner IRCCourt RulingsJan 21, 1998
… affect the jurisdiction of this Court. Rule 39; B adger
Mat erials, Inc. v. Commissioner
, 40 T.C. 1061, 1063 (1963);
Sutherland v. Commissioner
, T.C. Memo. 1996-1, affd. without
published opinion 111 F.3d 127 (3d Cir. 1997). Accordingly, were
we to agree with petitione r's argument (which we do not, as
explained inf…
IRCCourt RulingsJul 21, 1993related by meaning
ntered for respondent.
Except as otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year at issue. Sec. 1122(a)(2) of the Tax Reform Act of 1986 (TRA 1986), Pub. L. 99-514, 100 Stat. 2085, 2466, replaced the theretofore applicable 10-year averaging with 5-year averagi…
IRCCourt RulingsOct 2, 1974
…ng 37 T.C. 817 (1962); Time Oil Co. v. Commissioner, 258 F.2d 237 (C.A. 9, 1958), reversing 26 T.C. 1061 (1956); and Sachs v. Commissioner, 208 F.2d 313 (C.A. 3, 1953), reversing Slaymaker Lock Co., 18 T.C. 1001 (1952), dealing with the question of whether the transfer to an exempt trust of the employer-taxpayer’s prom…
IRCCourt RulingsMay 5, 1998
…sposition or beneficial enjoyment of trust
property. See United States v. Buttorff
, 761 F.2d 1056, 1061
(5th Cir. 1985); Schulz v. Commissioner
, 686 F.2d 490, 495 (7th
Cir. 1982), affg. T.C. Memo. 1980-568; Vnuk v. Commissioner
, 621
F.2d 1318, 1320 (8th Cir. 1980), affg. T.C. Memo. 1979-164.
Petitioners dealt with t…
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…
IRCCourt RulingsJun 7, 1984
…is attributable to the nonexempt life of the trust. See Johnson v. Commissioner, 74 T.C. 1057, 1059-1061 (1980), affd. 661 F.2d 53 (5th Cir. 1981), for a more detailed explanation of how such calculations are to be made, both for the year in which the contribution was made (1978), and for the subsequent years as to whi…
IRCCourt RulingsApr 30, 1964
…nt’s right to declare a once approved plan no longer approved and tax exempt. Time Oil Co., 26 T.C. 1061, remanded on other grounds 258 F. 2d 237 (C.A. 9). Here, however, we have no such alteration for tbe plan has been operated and administered in exact accordance ■with its provisions. In fact, only by an amendment of…
IRCCourt RulingsJun 18, 1997related by meaning
r personal injuries or
sickness to the extent such amounts are (A) attributable to
- 11 -
7
Former sec. 105(d) provided a limited exclusion from gross income for amounts received in lieu of wages prior to attaining
age 65 by completely disabled persons retired on disability.
Sec. 105(d) was repealed by sec. 122(b) of t…
IRCCourt RulingsOct 25, 1977
Citing Time Oil Co. v. Commissioner, 258 F.2d 237 (9th Cir. 1958), remanding 26 T.C. 1061 (1956), petitioners contend that disqualification of an employee plan under the exclusive benefit rule is appropriate only when there is a showing that the benefits to be received by the beneficiaries were somehow prejudiced. Peti…
IRCCourt RulingsJan 24, 1962
…1952), reversed snb nom. Sachs v. Commissioner, 208 F. 2d 313 (C.A. 3, 1953); Time Oil Co., 26 T.C. 1061 (1956), reversed and remanded 258 F. 2d 237 (C.A. 9, 1958). The decisions of this Court in the Slaymdker Lock Co. and Time Oil Co. cases, holding that the delivery of a demand promissory note did not constitute a pa…
IRCCourt RulingsJun 4, 1984
…Circuit’s decision in Time Oil Co. v. Commissioner, 258 F.2d 237 (9th Cir. 1958), remanding 26 T.C. 1061 (1956), is distinguishable. That case also involved the exclusive benefit rule, but in a context not involving trust investments. The Commissioner argued that the trust was not operated for the exclusive benefit of …
IRCCourt RulingsMay 14, 1974
…1952), reversed sub nom. Sachs v. Commissioner, 208 F. 2d 313 (C.A. 3, 1953); Time Oil Co., 26 T.C. 1061 (1956), revd. 258 F. 2d 237 (C.A. 9, 1958); Wasatch Chemical Co., 37 T.C. 817 (1962), revd. 313 F. 2d 843 (C.A. 10, 1963).
An appeal in the instant case would lie in the Court of Appeals for the Seventh Circuit whic…
IRCCourt RulingsJan 16, 2002related by meaning
470 in petitioner's
deductions, a $144 decrease in petitioner's withholding credits,
and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent
Spolse Relief, seeking equitable relief from liability under the
provisions of section 66(c). Respondent determ…
IRCCourt RulingsOct 29, 2013related by meaning
taxable year. Sec. 408(e)(2)(A). In such a case, the IRA in question will no
longer be exempt from tax under section 408(e)(1). Further, where such an account ceases to be an IRA by reason of section 408(e)(2)(A), the account is
deemed to have been distributed on the first day of the taxable year in an amount
equal to …
81 FR 84458 — Extension of Import Restrictions Imposed on Certain Archaeological and Ethnological Material From Greece IRCFinal Rules (FR)Nov 23, 2016related by meaning
above, part 12 of title 19 of the Code of Federal Regulations (19 CFR part 12), is amended as set forth below:
PART 12—SPECIAL CLASSES OF MERCHANDISE 1. The general authority citation for part 12 and the specific authority citation for § 12.104g continue to read as follows:
Authority:
5 U.S.C. 301; 19 U.S.C. 66, 1202 (…
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…
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, 2013related by meaning
unsel (Tax Exempt and Government Entities). However, other personnel from Treasury Department and the IRS participated in their development.
* * * * * [1] These proposed regulations apply solely for purposes of section 162(m)(6), and therefore have no effect on the determination whether an amount is remuneration attrib…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976
…stance is present. In Time Oil Co. v. Commissioner, 258 F.2d 237 (9th Cir. 1958), remanding 26 T.C. 1061 (1956), and Sherwood Swan & Co., 42 T.C. 299 (1964), affd. 352 F.2d 306 (9th Cir. 1965), also relied upon by the petitioner, it was found that the profit-sharing plan was not disqualified because of its operation. H…
IRCCourt RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…