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…
IRCPrivate Letter RulingsJun 11, 2004related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM
January 07, 2004
Number: 200424004
Release Date: 6/11/04
Third Party Contact:
Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04
CASE-MIS No.: TAM- 127815-03, CC:ITA:B07
Industry Director
------------------------------------------------
Taxpayer's Name…
73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner IRCCourt RulingsJan 31, 1980related by meaning
that in Community Services. Because that case was not decided under section 401(a)(7), its holding has no bearing on our decision of the instant case. Since the trustees are also shareholders, directors, and employees participating in the plan, petitioner contends that the State law principles of fiduciary duty prevent…
IRCCourt RulingsAug 26, 1963related by meaning
422, 441.
Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
86 FR 51730 — Requirements Related to Air Ambulance Services, Agent and Broker Disclosures, and Provider Enforcement IRCProposed Rules (FR)Proposed Sep 16, 2021
…cost of
reporting
Printing and materials cost
Total cost
45 CFR 148.410(c)(2)(i)—Issuers
0938-NEW
1,324
1,110,820
2
2,648
$143.18
$379,141
$333,246
$712,387
45 CFR 148.410(c)(2)(i)—Agents and Brokers
0938-NEW
55,541
55,541
0.5
27,771
66.44
1,845,072
0
1,845,072
45 CFR 148.410(c)(2)(ii), 148.410(c)(3)
0938-NEW
1,324
4,4…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
85 FR 57123 — Allocation of Assets in Single-Employer Plans; Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Sep 15, 2020
…rity:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, Rate Set 324 is added at the end of the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates for PBGC Payments
* * * * *
Rate set
For plans with a
valuation date
Immediate
annuity rate
(percent)
Deferred annu…
IRCCourt RulingsNov 6, 1962related by meaning
ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated.
Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act.
Thls section was originally desi…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
IRCCourt RulingsFeb 6, 1992related by meaning
fic terms and requirements that, in a reasonable manner, interpret and carry out the general concepts embodied in the statute and legislative history. Thus, we hold that the temporary regulation is valid.
Applicability of Temporary Regulation to Petitioner's Yearend Bonus Payments
In the alternative, petitioner argues …
IRCCourt RulingsFeb 9, 2023related by meaning
ement of this title, including all rules and regul ations as may be
necessary by reason of any alteration of law in relation to internal
revenue.”
108 Section 7805(b) of the Internal Revenue Code of 1954, 68A Stat.
at 917, was the provision in the Internal Revenue Code of 1954 that was
analogous to section 3791(b) of t…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsDec 29, 2005related by meaning
d the $1,916 payment as
a qualified retirement contribution to an individual retirement
account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA
contribution. In the opening brief, respondent argued that
section 219(g)(5) limits IRA deductions for active part…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner IRCCourt RulingsMay 29, 1968related by meaning
-10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
IRCCourt RulingsAug 8, 2005related by meaning
Commissioner
, 83 T.C.
755, 791 n.28 (1984); Kahler v. Commissioner
, 18 T.C. 31, 34-35
(1952); Roberts v. Commissioner
, T.C. Memo. 2002-281. In the instant case, the record reflects that the original check was not
subject to substantial limitations, and petitioner makes no
contention otherwise. Consequently, we find…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…
IRCCourt RulingsMay 14, 2001related by meaning
…ts constitute a division of marital property. Estate
of Goldman v. Commissioner
, 112 T.C. 317, 323-324 (1999), affd.
without published opinion sub nom. Schutter v. Commissioner
, 242
F.3d 390 (10th Cir. 2000).
The language of the decree also meets the requirement of 10
U.S.C. sec. 1408(a)(2)(C) (1994) for direct payme…
IRCCourt RulingsDec 8, 1987related by meaning
r the petitioner in docket No. 42535-84; decisions will be entered under Rule 155 in docket Nos. 42536-84, 42537-84, 42538-84, 42539-84, and 42540-84. AU statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue, unless otherwise indicated.
The Tax Equity and Fiscal Responsibi…