IRCPrivate Letter RulingsJun 22, 2001
…in LP-5 , and S-6 is the sole limited partner
with a ninety-nine percent interest in LP-5
.
Section 301.7701-2(a) provides that for purposes of § 301.7701-2 and
§ 301.7701-3, a business entity is any entity recognized for federal tax purposes
(including an entity with a single owner that may be disregarded as an entity…
PLR 201538020 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsSep 18, 2015
nder § 3121(b)(10), or (iv) normally work less than 20
hours per week.
Section 301.7701-1(a) of the P&A Regulations st ates that the classification of various organizations for federal tax purposes is determined under the Code, and does
not depend on whether the organization is recognized as an entity under local law.
…
IRCPrivate Letter RulingsFeb 6, 2015
…on or application for relief in respect
of tax under, among others, Subtitle A of the Code.
Section 301.9100-2 of the Regulations lists certain elections for which automatic
extensions
of time to file are granted. Section 301.9100-3 generally provides guidance
with respect to the granting
of relief with respect to thos…
IRCPrivate Letter RulingsNov 28, 2014
requests for
relief submitted to the Service on or after
December31, 1997.
Section
301.9100-1 (c) of the Regulations provides that the Commissioner of Internal Revenue, in his discretion, may grant a reasonable extension of the time
fixed by a
regulation, a revenue ruling, a revenue procedure, a notice, or an
announcem…
IRCPrivate Letter RulingsOct 17, 2014
…on or
application for relief in respect of tax under, among others, Subtitle A of the
Code. Section 301.9100-2
of the P&A Regulations lists certain elections for which
automatic extensions
of time to file are granted. Section 301.9100-3 generally
provides guidance with respect to the granting of relief with respect to …
76 FR 60373 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Sep 29, 2011related by meaning
…Drafting Handbook
for more details.
Department of the Treasury
Internal Revenue Service
26 CFR Part 301
[TD 9545]
RIN 1545-BG75
Correction
In rule document number 2011-21164 beginning on page 52259 through 52263 in the issue of August 22, 2011, make the following corrections:
301.6404-4
[Corrected]
1. On page 52262 in …
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014
…The running of any applicable period of limitations is not suspended for the period during which a §301.9100–1 request has been filed. See §301.9100–3(d)(2). If the period of limitations on an assessment under §6501(a) for the taxable year in which an election should have been made, or any taxable year that would have …
Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013
…he running of any applicable period of limitations is not suspended for the period during which a § 301.9100-1 request has been filed. See § 301.9100-3(d)(2). If the period of limitations on an assessment under § 6501(a) for the taxable year in which an election should have been made, or any taxable year that would hav…
IRCCourt RulingsDec 8, 1987related by meaning
tions. For such reason, the application cannot be deemed a return sufficient to start the 3-year statute of limitations running under section 6501(a). The final issue for our decision is whether section 4975 is an excise tax provision or a penalty provision. The petitioners argue that such section is intended to discou…
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
ngs and Agreements for extension of time for making an election or for other relief under § 301.9100–1 of the Procedure and Administration Regulations .03 With respect to recharacterization of a Roth IRA, Employee Plans Rulings and Agreements will consider a request for an extension of time for making an election or ot…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016related by meaning
ART 801—APPLICATION OF THE EMPLOYEE POLYGRAPH PROTECTION ACT OF 1988
31. The authority citation for part 801 is revised to read as follows:
Authority: Pub. L. 100-347, 102 Stat. 646, 29 U.S.C. 2001-2009; 28 U.S.C. 2461 note (Federal Civil Penalties Inflation Adjustment Act of 1990); Pub. L. 114-74 at § 701, 129 Stat 58…
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017
ngs and Agreements for extension of time for making an election or for other relief under § 301.9100–1 of the Procedure and Administration Regulations .03 With respect to recharacterization of a Roth IRA, Employee Plans Rulings and Agreements will consider a request for an extension of time for making an election or ot…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCProposed Rules (FR)Proposed Nov 20, 2023related by meaning
ent of Documents, U.S. Government Publishing Office, Washington, DC 20402, or by visiting the IRS website at
https://www.irs.gov.
Drafting Information The principal authors of these proposed are Elizabeth Boone and Hannah Kim, Office of the Associate Chief Counsel (Income Tax & Accounting), IRS, and Benjamin Weaver, Of…
89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024
any reportable transaction, as defined in § 1.6011-4(b), must file a return as described in § 301.6111-3(d) by the date described in § 301.6111-3(e). Section 301.6111-3(b)(1) provides that a person is a material advisor with respect to a transaction if the person provides any material aid, assistance, or advice with r…
89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities IRCFinal Rules (FR)Apr 25, 2024related by meaning
not impose substantial direct compliance costs on State and local governments, and do not preempt State law within the meaning of the Executive order. Statement of Availability of IRS Documents
IRS Revenue Procedures, Revenue Rulings, Notices, and other guidance cited in this document are published in the Internal Reve…
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
…
IRCCourt RulingsJan 12, 1998related by meaning
, 3207-22,
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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 …
Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2022
…r a request for an extension of time for making an election or other application for relief under § 301.9100-1 even if submitted after the return covering the issue presented in the § 301.9100-1 request has been filed and even if submitted after an examination of the return has begun or after the issues in the return a…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…