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81 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 54.4975-7(a) — Other statutory exemptions.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) [Reserved]
  2. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024related by meaning
    is obtained on or before the date the IRS issues a notice of deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 …
  3. I.R.C. § 6662(d)(2)(B)(ii)(I) — Imposition of accuracy-related penalty on underpayments
    IRCCode / StatuteJan 5, 2023related by meaning
    (d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and (d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer. (d)(2)(C) (C) Reduction not to apply to tax shelters (d)(…
  4. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023
    …t “must have ‘complete power’ to shift income among its subsidiaries.” Id. at 404- 05, 92 S. Ct. at 1091- 92 (quoting 26 C.F.R. § 1.482-1(b)(1) (1971)). Moreover, the regulations and First Security make clear that this standard is not limited to cases where the government contends the taxpayer attempted to evade taxes.…
  5. Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona…
    IRCNoticesModified Dec 22, 2008
    …ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
  6. T.D. 9223 — Final regulations under section 402 of the Code address the amount includible in a distributee’s income when life insurance contracts are distributed by a qual…
    IRCTreasury DecisionsSep 26, 2005related by meaning
    also be used to furnish the donor of a qualified vehicle with a contemporaneous written acknowledgment. EXCISE TAX Rev. Rul. 2005-64 Rev. Rul. 2005-64 Interaction of sections 469 and 4261. This ruling describes the circumstances in which losses incurred by an individual who provides air transportation through a passthr…
  7. 72 T.C. 1088; 1 Employee Benefits Cas. (BNA) 1830 — Caterpillar Tractor Co. v. Commissioner
    IRCCourt RulingsSep 13, 1979
    … the clear import of the previously quoted language of the first sentence of section 411(a). See p. 1091 supra.
  8. Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4…
    IRCNoticesObsolete Dec 26, 2007
    …ecurities and Exchange Commission under § 16 of the Securities Exchange Act of 1934, as amended, 15 USC 78p, without regard to whether the service recipient has any class of equity securities registered under § 12 of such Act, 15 USC 78l. See 17 CFR § 240.16a-1(a) (beneficial owner) and (f) (officer). In the case of a …
  9. Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr…
    IRCAnnouncementsMay 9, 2005
    …ALTH PLANS Par. 1. The authority citation for part 2590 continues to read as follows: Authority: 29 USC 1027, 1059, 1135, 1161-1168, 1169, 1181-1183, 1181 note, 1185, 1185a, 1185b, 1191, 1191a, 1191b, and 1191c, sec. 101(g), Public Law 104-191, 101 Stat. 1936; sec. 401(b), Public Law 105-200, 112 Stat. 645 (42 USC 651 …
  10. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  11. 76 FR 13932 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations
    IRCProposed Rules (FR)Proposed Mar 15, 2011
    …, 83 Stat. 523) and significantly amended by section 1224(a) of the PPA (Pub. L. 109-280, 120 Stat. 1091).
  12. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    statutory notice of deficiency was issued more than 6 years after petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations as an affirmative defense in its pleadings for the taxable year at issue. Accordin…
  13. ERISARegulationsJan 1, 2017related by meaning
    [Reserved]
  14. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    ERISACourt RulingsAug 14, 2026
    …same essential characteristics as the claims of the class at large.” Scott v. Dart , 99 F.4th 1076, 1091–92 (7th Cir. 2024) (citation modified). In the district court’s view, Kaiser’s claims were identical to those of the putative class: she was entitled to retiree healthcare benefits because the objective evidence evinc…
  15. T.C. Memo. 1997-556 — A. C. Green Electrical Contractors, Inc. v. Commissioner
    IRCCourt RulingsDec 22, 1997
    …er v. ICI Americas, Inc. , 70 F.3d 281, 288 (3d Cir. 1995); Sayers v. Rochester Tel. Corp. , 7 F.3d 1091, 1094-1095 (2d Cir. 1993); Pizzuti v. Polaroid Corp. , 985 F.2d 13, 14 (1st Cir. 1993). Language used in employee benefit plans is generally interpreted according to its common and ordinary meaning, and an effort is…
  16. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
  17. T.C. Summary Opinion 2016-40 — Paul Parisi v. Commissioner
    IRCCourt RulingsAug 9, 2016
    …t an eligible institution of higher education. See secs. 529(e)(3)(B)(i), 25A(b)(3); 20 U.S.C. sec. 1091(a)(1) (2006). 5(...continued) plans that meet the sec. 7701(a)(37) definition of an individual retirement plan, i.e., individual retirement accounts and individual retirement annuities. - 8 - Petitioner argues that …
  18. T.C. Memo. 2013-126 — Laura Ung v. Commissioner
    IRCCourt RulingsMay 13, 2013
    …antially more, constitute or establish either legal or equitable homeownership. Cal. Civ. Code sec. 1091 (West 2007) ("An estate in real property * * * can be transferred only by operation of law, or by an instrument in writing."). On the basis of the record, we find that petitioner did not hold an ownership interest i…
  19. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    …ing the assessment or collection of any tax. Id. at 737, 749; see also Maze v. IRS , 862 F.3d 1087, 1091 (D.C. Cir. 2017); Cohen v. United States, 650 F.3d 717, 729 (D.C. Cir. 2011). In Williams Packing & Navigation Co. , 370 U.S. at 7, the Supreme Court stated that if the judicial exception to the AIA did not apply th…
  20. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    ies. Subchapter C, consisting solely of section 6751, sets forth “Procedural Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…