IRCCourt RulingsNov 26, 1969
…es in its service. United States v. Martin, 337 F. 2d 171 (C.A. 8, 1964); United States v. Peebles, 331 F. 2d 955 (C.A. 5, 1964); United States v. Johnson, 331 F. 2d 943 (C.A. 5, 1964) ; Jack E. Schlegel, 46 T.C. 706, 708 (1966); see also E. N. Funkhouser, 44 T.C. 178 (1965), aff'd. 375 F. 2d 1 (C.A. 4, 1967); Victor S…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…in payment of a “substantial number” of future premiums on such a contract.
(47) Sections 267, 304, 331, 332, 351, and 1502.—Losses, Expenses, and Interest with Respect to Transactions Between Related Taxpayers; Redemption Through Use of Related Corporations; Gain or Loss to Shareholder in Corporate Liquidations; Compl…
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
… that the suggested changes are inconsistent with the general principle in the Act and in 31 CFR 29.331. Section 29.331 provides that all requirements must be satisfied as of June 30, 1997, for service to be creditable towards a Federal Benefit Payment. In turn, the general principle is consistent with section 11012(b)…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…02(e)(2) business terminations are not subject to this provision.)
(23) Sections 302(b)(4) and (e), 331, 332, and 346(a).—Effects on Recipients of Distributions in Corporate Liquidations.—The tax effect of the liquidation of a corporation preceded or followed by the transfer of all or a part of the business assets to a…
IRCCourt RulingsDec 31, 1957related by meaning
y its shareholders, partners, or beneficiaries.
Sec. 430 (e) (1).
As stipulated.
Sec. 430 (e) (2) (B).
Sec. 430 (e) (2) (B) (1).
Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
IRCCourt RulingsAug 27, 2026
…ments is another factor that supports a
finding of fraudulent intent) , aff’d per curiam , 748 F.2d 331 (6th Cir.
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…would be able to sell. Mr. Partlow estimated the maximum
amount that could be sold per year was 353,331 tons .
3. Ryan Taylor
Ryan Taylor has worked as a geologist since 2001. He is a
registered professional geologist in the State of Georgia. Currently, he
is a Program Lead and Professional Geologist with the Division …
IRCCourt RulingsSep 30, 1985related by meaning
ution for the taxable year, reduced (but not below zero) by
(ii) 20 percent of the amount (if any) by which such total taxable amount exceeds $20,000. (E) Liability for tax. — The recipient shall be liable for the tax imposed by this paragraph.
Sec. 402(e)(4)(A) provides in pertinent part:
(4) Definitions and special r…
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
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCProposed Rules (FR)Proposed Nov 27, 2019
… Departments estimate the total one-time hour burden for all health insurance issuers and TPAs of 2,331,210 hours and an associated equivalent cost of approximately $211,386,679 to develop and build the Negotiated Rate File in a machine-readable format. In subsequent years, the Departments estimate the total annual hou…
87 FR 62316 — Actuarial Assumptions for Determining an Employer's Withdrawal Liability PBGCProposed Rules (FR)Proposed Oct 14, 2022
…appeals filed,
Nos. 21-55864, 21-55923;
Manhattan Ford Lincoln, Inc.
v.
UAW Local 259 Pension Fund,
331 F. Supp. 3d 365 (D.N.J. 2018) (re blended rates),
appeal voluntarily dismissed; New York Times Co.
v.
Newspaper and Mail Deliverers'-Publishers' Pension Fund,
303 F. Supp. 3d 236 (S.D.N.Y. 2018) (re blended rates),
a…
IRCCourt RulingsApr 22, 1992related by meaning
tatutoiy references are to the Internal Revenue Code in effect for 1986, and all Rule references are to the Tax Court Rules of Practice and Procedure. he parties have stipulated as follows:
8. During 1986, the petitioner, due to his termination of employment * * * received a total distribution from his employer's Incen…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…llection,[329]
ACA Medical Loss Ratio (MLR) Reporting,[330]
Medicare Part D Reporting Requirements,[331]
and the Hospital Price Transparency Requirements.[332]
Of these rules, the IT costs associated with Prescription Drug Data Collection rule seemed most analogous to this proposed rule, as it specifically identified c…
76 FR 66136 — Investment Advice-Participants and Beneficiaries ERISAFinal Rules (FR)Oct 25, 2011
…terba
et al., Asset Location for Retirement Savers, inPublic Policies and Private Pensions
290, 290-331 (John B. Shoven
et al.
eds., 2004); John B. Shoven & Clemens Sialm,
Asset Location in Tax-Deferred and Conventional Savings Accounts,
Journal of Public Economics, Volume 88 (2003); James M. Poterba
et al., Asset Loca…
IRCCourt RulingsNov 24, 1971
er Ward T. Richards on or about August 3, 1967, and the amount of $4,331.67 was distributed to petitioner Homer N. Ackerman on or about August 3,1967. In connection with the distributions on or about August 3, 1967, petitioners Homer N. Ackerman and Ward T. Richards each received a letter dated August 3, 1967, from the…
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 RulingsJan 14, 2013
…number. No Forms W2 were presented for any year where the amount paid was "-0-".
- 9 -
[*9] 1994 23,331 -01995 25,885 -01996 1 26,500 -01997 26,500 -01998 i 26,500 -01999 26,112 3,112
2000 J 25,072 19,669
2001 25,011 26,000
2002 } 129,030 130,000
Total 512,985 315,699
The corporation did not begin to cover its expenses…
IRCCourt RulingsApr 26, 1983related by meaning
tions of Beneficiaries hereunder, shall be included as additional Beneficiaries.
% * * * s¡c sfc
Article V
PROVISIONS RE ACCUMULATION AND DISTRIBUTION This Trust is in part an accumulation Trust, and in part for current distribution of income and corpus. Distributions, and matters relating thereto, shall be governed as…
76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner IRCCourt RulingsMar 17, 1981related by meaning
implement the congressional mandate in some reasonable manner.’ ” (Citations omitted.) Commissioner v. Portland Cement Co. of Utah, 450 U.S. _ (1981). H. Rept. 2333,77th Cong., 1st Sess. (1942), 1942-2 C.B. 372,413; S. Rept. 1631, 77th Cong., 2d Sess. (1942), 1942-2 C.B. 541, 606-607. The specific changes made by Congr…