IRCCourt RulingsSep 13, 2004
…e taxpayer
of the persons involved in the expense. The term "listed
property" is defined in section 280F(d) and includes passenger
vehicles. See sec. 280F(d)(4)(A)(i).
Under section 274(d), substantiation by means of adequate
records requires a taxpayer to maintain a diary, a log, or a
similar record, and documentary e…
IRCCourt RulingsJul 26, 1989related by meaning
June 19, 1986, the Court of Appeals affirmed our decision sub nom. Dillon v. United States, 792 F.2d 849 (9th Cir. 1986).
The parties also stipulated: Petitioners accept the determination of tax contained in the deficiency notice as mathematically correct, except they contend that the tax should be computed by applying…
IRCCourt RulingsMay 22, 2025related by meaning
waived a procedural challenge to Temp. Treas. Reg. § 1.482-7T.
It did not waive a substantive challenge that the regulations reach an outcome that is not permitted by statute either on their face or as applied to petitioner. See Order,
September 23, 2022 (Docket Index No. 596).
118
with a brief history of the statute …
IRCCourt RulingsMar 7, 2019
…ayer must meet section 274(d)'s
heightened substantiation requirements. See secs. 274(d)(4) (2008), 280F(d)(4);
see also, e.g., WSK & Sons, Inc. v. Commissioner, T.C. Memo. 2015-204, at *12-
*13 (outlining section 274(d) requirements for passenger automobiles).
- 27 -
[*27] The parties stipulated before trial a list of…
Joint BoardRegulationsOct 11, 2017related by meaning
(b) (b) Effective/applicability date. This section is applicable to conduct occurring on or after September 26, 2007.
IRCCourt RulingsJul 11, 2002
…y,
(3) for any expense for gifts, or
(4) with respect to any listed property (as
defined in section 280F(d)(4)),
unless the taxpayer substantiates by adequate records
or by sufficient evidence corroborating the taxpayer’s
own statement (A) the amount of such expense or other
item, (B) the time and place of the travel,
…
IRCCourt RulingsJan 12, 1998related by meaning
, 3207-22,
- 7 -
3
U.S. Const. amend. V provides "nor shall any person be
subject for the same offence to be twice put in jeopardy of life
or limb".
4 U.S. Const. amend. VIII provides "Excessive bail shall
not be required, nor excessive fines imposed".
we think it clear that allowance of petitioner's claimed
deduction …
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 …
78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property IRCFinal Rules (FR)Sep 19, 2013
…xable year;
(C) Passenger automobiles for which the depreciation allowance is limited under section 280F(a) must be grouped into a separate multiple asset account or pool;
(D) Assets not eligible for any additional first year depreciation deduction (including assets for which the taxpayer elected not to deduct the addi…
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 …
PBGCRegulationsAug 8, 2022related by meaning
(g) (g) If any provision in this part is held to be invalid or unenforceable by its terms, or as applied to any person or circumstance, or stayed pending further agency action, the provision will be construed so as to continue to give the maximum effect to the provision permitted by law, unless such holding will be one…
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 …
IRCCourt RulingsMay 31, 1989related by meaning
nal Revenue Code of 1954 as amended and in effect at the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Sec. 7482(b)(1)(A) establishes venue for appeal in the case of a petitioner other than a corporation. While the parties stipulated that petitioner’s principal office was…
IRCCourt RulingsSep 2, 2021
…ating to travel, m eals
and entertainm ent, gifts, or other “listed property” as defined in section
280F(d)(4)), a taxpayer m ust m eet the strict substantiation requirem ents set out in
- 15 -
[*15] section 274. To satisf y the strict substantiation requirem ents, a taxpayer
m ust introduce sufficient evidence to corr…
IRCCourt RulingsFeb 6, 2024related by meaning
Tax Court Rules of Practice and Procedure. Except where
otherwise indicated, all monetary amounts are rounded to the nearest dollar.
Served 02/06/24
2 [* 2 ] failure to file and failure to pay addition s to tax for petitioner’ s 2017
tax year .
2
T he issue s for decision are whether (1) petitioner is liable for tax
wi…
IRCCourt RulingsNov 3, 2008
… expenses ;
(3) any expense for gifts ; or (4) the use of listed,property, , as'
defined in section 280F(d)(4), including passenger automobiles .`
To deduct such expenses, the taxpayer must substantiate by
adequate : records or evidence sufficient to corroborate the
taxpayer's own testimony : . (1) The amount of the ex…
IRCCourt RulingsDec 18, 2012
…e estimated because of the strict substantiation requirements of
section 274(d).. See secs. 274(d), 280F(d)(4); Sanford v. Commissioner, 50 T.C.
823, 827-828 (1968), aff'd per curiam, 412 F.2d 201 (2d Cir. 1969). To
substantiate a deduction for those expenses, a taxpayer must maintain adequate
records or present eviden…
89 FR 104915 — Regulations Governing Practice Before the Internal Revenue Service IRCProposed Rules (FR)Proposed Dec 26, 2024related by meaning
will not bar any proceeding under subpart F but will preclude the use of a copy of the report in a proceeding under subpart F.
(e)
Applicability date. This section is applicable to conduct occurring on or after [date 30 days after date of publication of final regulations in the
Federal Register
].
Par. 34.
Add subpart …
IRCCourt RulingsOct 28, 1997
…ed with respect to certain listed
property. Sec. 274(d). Listed property includes automobiles.
Sec. 280F(d)(4). Section 274(d) requires substantiation of these
expenses either "by adequate records or by sufficient evidence
corroborating the taxpayer's own statement". Sec. 274(d).
Rental Expenses
Section 469 limits the …
IRCCourt RulingsApr 16, 2020
…passenger automobile that falls within the definition of listed property under
- 23 -
[*23] section 280F(d)(4) and (5). Therefore, petitioners' depreciation deduction
for this vehicle is subject to the strict substantiation requirements of section
274(d).
Petitioners provided no document that qualifies as an adequate r…