IRCCourt RulingsDec 16, 1998
…ion
6651(a)(1) for an addition to that year's tax. Although
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6
Sec. 291 of the Revenue Act of 1928, ch. 852, 45 Stat.
857, provides:
In case of any failure to make and file a return
required by this title, within the time prescribed by
law * * *, 25 per centum of the tax shall be added to
the tax, except that whe…
87 FR 80042 — Exception for Interests Held by Foreign Pension Funds IRCFinal Rules (FR)Dec 29, 2022related by meaning
ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development.
( printed page 80055) List of Subjects in 26 CFR Part 1
Income taxes
Reporting and recordkeeping requirements
Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended a…
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 …
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 …
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 …
IRCRegulationsDec 30, 2016
…the Social Security Act (Medicaid), other than coverage consisting solely of benefits under section 1928 of the Social Security Act (the program for distribution of pediatric vaccines).
IRCPrivate Letter RulingsDec 20, 2013
…e net cost of the policy from gross income as a loss.
The basis under se ction 113(a) of the Act of 1928 for purposes of determining gain or
loss from the sale or disposition of property acquired after February 28, 1913, is the cost
of such property. The court determined that that the cost of the proceeds which the
tax…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…ction as a whole, with all of its subsections in mind. See
Hellmich v. Hellman
, 276 U.S. 233, 237 (1928); H uffman v.
Commissioner
, 978 F.2d 1139, 1145 (9th Cir. 1992), affg. in part,
revg. and remanding in part T.C. Memo. 1991-144.
5. The Statute
We begin with the specific language of section 419 A(c)(2),
which prov…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJul 31, 2000
…ly listed on Ms. Lo’s
policy as the beneficiary thereof. See Rieck v. Heiner
, 25 F.2d
453 (3d Cir. 1928).
Dr. Lo, as opposed to Edward Lo, also stood to gain the most
from the plan assets, were Ms. Lo to have died. Whereas Edward
Lo had a fairly inexpensive term life insurance policy, Dr. Lo
had a fairly expensive uni…
IRCCourt RulingsFeb 26, 2014
…. Labs., Inc. v. Commissioner, 10 T.C. 279, 288 (1948), and
Elkins v. Commissioner, 12 B.T.A. 1058 (1928)).
Petitioners' case is not like Wood. The $36,000 was not in fact deposited
within the statutorily prescribed 60-day.period; any "error" that may have been
committed by Schwab was not a bookkeeping error.
Although …
IRCCourt RulingsFeb 28, 2024
… only on the government.” Id. (first
citing United States v. Magnolia Petroleum Co. , 276 U.S. 160 (1928); and
then citing Whit e v. United States, 191 U.S. 545 (1903)).
Unlike the statute at issue in Magnolia Petroleum , which addressed the payment of interest on a refund claim and affected how
much interest the taxpa…
IRCCourt RulingsAug 13, 1999
…
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7
The predecessor to sec. 404 first appeared in the Code as
sec. 23(p) of the Revenue Act of 1928, ch. 852, 45 Stat. 791,
799-802. Before adoption of the Revenue Act of 1942, ch. 619, 56
Stat. 798, contributions made to employees' deferred compensation
funds could be deducted either as "ordinary and necessary"
b…
88 FR 11388 — Extension of Import Restrictions on Archaeological and Ethnological Materials of Libya IRCFinal Rules (FR)Feb 23, 2023related by meaning
nction of the United States, as described above, and therefore is specifically exempted by section 3(d)(2) of Executive Order 12866.
Signing Authority This regulation is being issued in accordance with 19 CFR 0.1(a)(1), pertaining to the Secretary of the Treasury's authority (or that of his/her delegate) to approve reg…
T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner IRCCourt RulingsApr 27, 1998
…. Co. v. United States
, 251 U.S. 342, 346-347 (1920);
Wilson v. Commissioner
, 12 B.T.A. 403, 405 (1928) ("It is a well
established principle of law that receipt by an agent is receipt
by the principal.").
Before a 1993 change in New York law which broadened the
powers of a temporary administrator, temporary administr…
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…
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, 2024related by meaning
ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
T.D. 9294 — Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recip… IRCTreasury DecisionsNov 27, 2006related by meaning
lans.
* * * * *
Par. 9. Section 1.7476-2 is amended by revising paragraph (c)(2) to read as follows:
§1.7476-2 Notice to interested parties.
* * * * * (c) * * *
(2) If the notice to interested parties is delivered using an electronic medium under an electronic system that satisfies the applicable notice requirements of…
IRCCourt RulingsJan 31, 1973
…. Lincoln Savings & Loan Assn., 403 U.S. 345, 359 (1971). In Spring Canyon Coal Co., 13 B.T.A. 189 (1928), affd. 43 F. 2d 78 (C.A. 10, 1930), certiorari denied 284 U.S. 654 (1931), we held that amounts paid into a reserve by a taxpayer as a self-insurer under the Utah Workmen’s Compensation Act were not deductible from…
IRCCourt RulingsJul 26, 2012
…. Labs., Inc. v. Commissioner, 10 T.C. 279, 288
(1948), and Elkins v. Commissioner, 12 B.T.A. 1058 (1928)).
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Petitioners' reliance on Wood is misplaced. Generally, this Court applies
the doctrine of substantial compliance "to excuse taxpayers from strict compliance
with procedural regulatory requirements". Dirks v…