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Go to 77 T.C. 145 (not yet in the library — opens the official source)
77 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  2. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
  3. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  4. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    Internal Revenue Code . Accordingly, petitioner is liable for the section 6662 penalty . In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is i 6 - imposed upon such distributions unless the distributions meet the requirements of one of the exce…
  5. T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov…
    IRCTreasury DecisionsAug 15, 2016related by meaning
    ction be submitted with the taxpayer’s income tax return for the taxable year in which the property is transferred. EMPLOYEE PLANS T.D. 9779 T.D. 9779 Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service provider to el…
  6. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    lating to petitioners' loan, 10.5 percent is the fair market interest rate. V. Addition to Tax Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to file Form 5330 for each taxable year, or portion thereof, in the taxable period. Sec. 6011; sec. 54.6011-1(…
  7. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
  8. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    … response (hours) Total annual burden (hours) Printing and material costs Total estimated cost 2021 145,887 (All Physicians) 145,887 2.5 364,717 $61,797,674 2021 116,709 * (Additional burden for Subset of Physicians with Websites) * 116,709 1 116,709 13,278,038 Total 3.5 481,426 ** 75,075,712 * This is calculated as th…
  9. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001related by meaning
    claim to a pension plan contribution deduction on that ground forecloses her claim that she is entitled to an above-the-line Schedule C deduction for legal fees, rather than the itemized deduction subject to the 2percent limitation of section 67 that respondent allowed in the statutory notice. To give effect to all the…
  10. 79 FR 76931 — Amendments to Excepted Benefits
    IRCProposed Rules (FR)Proposed Dec 23, 2014
    …ce coverage). Back to Citation 11.  26 CFR 54.9831-1(c)(3)(v); 29 CFR 2590.732(c)(3)(v); 45 CFR 146.145(b)(3)(v). Back to Citation 12.  See the discussion in the 2014 final regulations concerning the application of these requirements to benefits such as limited-scope dental and vision benefits and employee assistance p…
  11. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997related by meaning
    Motion for a Section 6673 Penalty Respondent submitted a motion for the imposition of a penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an amount not to exceed $25,000 whenever it appears that the taxpayer's position in a proceeding is frivolous,…
  12. T.C. Memo. 2018-155 — Ruben De Los Santos & Martha De Los Santos v. Commissioner
    IRCCourt RulingsSep 18, 2018
    …e recipients is the beneficiary of the death benefit" for purposes of the split-dollar regulations. 145 T.C. at 44-45.3 In sum, we conclude that the arrangement at issue satisfied all three criteria required to create a compensatory arrangement under the regulations. We accordingly hold that the Policy issued on petiti…
  13. 81 FR 75316 — Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance
    IRCFinal Rules (FR)Oct 31, 2016
    …rm, limited-duration insurance” in § 144.103 of this subchapter and paragraph (c)(5)(i)(C) of § 146.145 apply for policy years and plan years beginning on or after January 1, 2017. 15. Section 146.145 is amended by adding paragraph (b)(2)(ix) and revising paragraph (b)(5)(i)(C) to read as follows: § 146.145 Special rul…
  14. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974related by meaning
    ew principal place of work. Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217. SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
  15. 81 FR 38020 — Expatriate Health Plans, Expatriate Health Plan Issuers, and Qualified Expatriates; Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Dura…
    IRCProposed Rules (FR)Proposed Jun 10, 2016
    …d)(2)(ii)(B). Back to Citation 12.  26 CFR 54.9831-1(c)(3)(v), 29 CFR 2590.732(c)(3)(v), 45 CFR 146.145(b)(3)(v). Back to Citation 13.  PHS Act section 2722(c)(1), ERISA section 732(c)(1), Code section 9831(c)(1). Back to Citation 14.  26 CFR 54.9831-1(c)(4)(i), 29 CFR 2590.732(c)(4)(i), 45 CFR 146.145(b)(4)(i). Back t…
  16. Treas. Reg. § 1.404(a)-13(c) — Contributions of an employer where deductions are allowable under section 404(a) (1) or (2) and also under section 404(a)(3); application of section 404(a)(7).
    IRCRegulationsMay 18, 2016
    …r 2 275 250 225 150 (b) Total amount otherwise deductible for year: item 5 plus item 11 375 240 235 145 (c) Smaller of (a) or (b) 275 240 225 145 (ii) Carryover from prior years under section 404(a)(7) 0 100 40 10 (iii) Sum of (i)(c) and (ii) 275 340 265 155 (3) Amount deductible: Lesser of (1) or (2)(iii) 275 300 265 …
  17. T.C. Memo. 2016-55 — Brenda S. Jones v. Commissioner
    IRCCourt RulingsMar 28, 2016
    …de by the Commissioner and rejected by the Court in Our Country Home Enters., Inc. v. Commissioner, 145 T.C. at __ (slip op. at 65). Thus, petitioners urge us to apply only the split-dollar life insurance arrangement regulations in these consolidated cases. Petitioners' position is flawed in several respects. First, th…
  18. Treas. Reg. § 1.409(p)-1(h) — Prohibited allocation of securities in an S corporation.
    IRCRegulationsMay 18, 2016
    … outstanding shares (the 100 shares owned directly by B, B's 330 deemed-owned ESOP shares, plus C's 145 deemed-owned ESOP shares equal only 47.9% of the 1,200 outstanding shares of X). Example 2. Relating to determination of disqualified persons and nonallocation year if there is synthetic equity.(i) Facts. The facts a…
  19. Treas. Reg. § 1.409(p)-1T(h) — Prohibited allocations of securities in an S corporation (temporary).
    IRCRegulationsMay 18, 2016
    … outstanding shares (the 100 shares owned directly by B, B's 330 deemed-owned ESOP shares, plus C's 145 deemed-owned ESOP shares equal only 47.9% of the 1,200 outstanding shares of X). Example 2. Relating to determination of disqualified persons and nonallocation year if there is synthetic equity.(i) Facts. The facts a…
  20. T.C. Summary Opinion 2017-64 — Wilfred Omoloh v. Commissioner
    IRCCourt RulingsAug 16, 2017related by meaning
    en of proving that those determinations are erroneous.4 See Rule 142(a); Welch v. Helvering, 290 U.S. I11, 115 (1933). I. Section 72(t) Additional Tax Section 72(t)(1) imposes an additional tax on an early distribution from a qualified retirement plan equal to 10% of the portion of the amount that is includable in gros…