ERISARegulationsJan 1, 2017related by meaning
[Reserved]
T.D. 10001 — These regulations provide guidance related to section 401 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), enacted on Dec… IRCTreasury DecisionsAug 12, 2024related by meaning
isted transactions would be required to file disclosures with the IRS and would be subject to penalties for failure to disclose.
T.D. 10004, page 489. This document contains final regulations regarding the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizat…
PBGCRegulationsDec 7, 2023related by meaning
[Reserved]
IRCCourt RulingsOct 25, 1961related by meaning
ment Commission is correct, and we also do not decide whether the allocation conforms to the partnership agreement or to proper accounting principles. Because petitioners concede that the certificate of disallowance has the effect of reducing their net operating loss for tax purposes below the amounts claimed by them i…
IRCProposed Rules (FR)Proposed May 13, 2026
…pted fertility benefits coverage, resulting in an estimated 743,361 individuals enrolling annually.[154]
The Departments acknowledge the uncertainty around this estimate of the number of individuals that would enroll and request comment on ways to improve it.
G. Requests for Comments
The Departments invite comments add…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner IRCCourt RulingsApr 27, 1998
T.C. Memo. 1998-154
UNITED STATES TAX COURT
ESTATE OF MARTIN J. MACHAT, DECEASED, AVRIL GIACOBBI AND
ERIC R. SKLAR, EXECUTORS, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21573-96. Filed April 27, 1998.
Richard S. Kestenbaum
and Bernard S. Mark
, for petitioner.
Janet F. Appel
and Donald A. G…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsMay 29, 2002related by meaning
is Court.
Section 72(t) provides that:
(1) * * * If any taxpayer receives any amount from a
qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount
equal to 10 percent of the portion of such amount which is
includible in gross income.
Section 72(t)(2) provides…
IRCCourt RulingsApr 2, 2020
…Commissioner, T.C.
Memo. 1957-129, aff'd in part, rev'd in part, 266 F.2d 698 (9th Cir. 1959). It
- 154 -
[*154] seems that the Office of Appeals determined that the report (i.e., the May
2011 Form 4549) was not conclusive as to Goldberg's liability for interest.
The notice of determination briefly touched on Goldberg'…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCFinal Rules (FR)Oct 8, 2019
…rivate sector, of $100 million or more in any one year (adjusted annually for inflation, currently $154 million).[107]
As discussed in the OCC's Regulatory Flexibility Act section, the costs associated with the final rule, if any, would be
de minimis.
Therefore, the OCC concludes that the final rule will not result in …
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
INCOME TAX
Rev. Rul. 2007-50 Rev. Rul. 2007-50
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for August 2007.
T.D. 9329 T.D. 9329
Final regulations under sect…
IRCCourt RulingsOct 28, 1987
…sen v. Commissioner
Docket No. 4909-86
United States Tax Court
89 T.C. 939; 1987 U.S. Tax Ct. LEXIS 154; 89 T.C. No. 65;
October 28, 1987; As amended December 7, 1987 October 28, 1987, Filed
*154 Decision will be entered under Rule 155.
Decedent died testate on Apr. 20, 1982, survived by his wife and six children. His …
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…ice and for each plan, insurance policy, or coverage included in an aggregated Allowed Amount File.[154]
The Departments finalized this requirement in the 2020 final rules because if the threshold were applied to the aggregated claims data at the service provider level, rather than for each plan or coverage as is requi…
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
…O REVENUE PROCEDURE 2017–4?
153
.01 In general
153
.02 Changes related to pre-approved plan program
154
.03 Changes to fees for EP VCP Submissions
154
.04 Changes to other fees
155
.05 Other changes
155
PART I. GENERALLY APPLICABLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGRE…
Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl… IRCRevenue RulingsMar 8, 2004
Rul. 66-110, as amplified by Rev. Rul. 67-154, for periods after December 31, 2003, with respect to arrangements entered into after January 28, 2002. Rev. Rul. 2003-105, 2003-40 I.R.B. 696, obsoleted Rev. Rul. 66-110 for arrangements entered into after September 17, 2003, except as provided in paragraph 3 of Section I…
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
IRCCourt RulingsSep 24, 2026
…
Examination Division ’ s determination to assert a penalty. See Belair
Woods, LLC v. Commissioner, 154 T.C. 1, 15 (2020) .
Petitioner does not dispute that the IRS met these requirements
here. The IRS secured managerial approval of the penalty on May 20 ,
202 4, when the revenue agent’s manager noted in the examinatio…