IRCCourt RulingsJul 2, 2003
…erved. Taylor v. Commissioner
, 67 T.C. 1071, 1077 (1977);
Sperapani v. Commissioner
, 42 T.C. 308, 331 (1964). On the other
hand, if the requirements are procedural or directory in that
they do not go to the essence of the thing to be done, but rather
- 8 -
are given with a view to the orderly conduct of business, the…
IRCCourt RulingsJan 14, 2013★ strong match
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
IRCCourt RulingsJan 28, 2002
… was retired and lived in Mississippi when he
filed the petition.
In 1998, petitioner received $217,331.44 in retirement
distributions and $920.09 in nonemployee compensation. In 1998,
Primerica Life Insurance Co. issued to petitioner three Forms
1099-MISC, Miscellaneous Income, which state that he received
$920.09 of …
64 T.C. 1011 — Catawba Industrial Rubber Co. v. Commissioner IRCCourt RulingsSep 9, 1975
…meet the requirements of sec. 401(a)(3), (4), (5), and (6) in sec. 401(b). See Aero Rental, 64 T.C. 331 (1975). Respondent agrees that this fact alone would not negative the existence of a qualified trust in petitioner’s fiscal year 1972, if a contribution was made to an existing trust within the grace period provided …
IRCCourt RulingsJun 14, 1982related by meaning
nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case.
Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
IRCCourt RulingsJul 24, 1995
…bserved. Taylor v. Commissioner, 67 T.C. 1071, 1077 (1977); Sperapani v. Commissioner, 42 T.C. 308, 331 (1964). On the other hand, if the requirements are procedural or directory in that they do not go to the essence of the thing to be done, but rather are given with a view to the orderly conduct of business, they may …
IRCCourt RulingsMar 27, 1989related by meaning
ended returns, The conditions were not met, and it was not an abuse of discretion to disqualify the plan.
Revocation of Favorable Determination Letter The Supreme Court has held that the Commissioner has broad discretion under section 7805(b) in deciding whether to revoke a ruling retroactively, and that his determinat…
IRCCourt RulingsNov 26, 1969
…es in its service. United States v. Martin, 337 F. 2d 171 (C.A. 8, 1964); United States v. Peebles, 331 F. 2d 955 (C.A. 5, 1964); United States v. Johnson, 331 F. 2d 943 (C.A. 5, 1964) ; Jack E. Schlegel, 46 T.C. 706, 708 (1966); see also E. N. Funkhouser, 44 T.C. 178 (1965), aff'd. 375 F. 2d 1 (C.A. 4, 1967); Victor S…
IRCCourt RulingsJul 24, 1984related by meaning
rectly involved in such ruling. * * *”
See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …
IRCCourt RulingsJun 16, 1987related by meaning
GOFFE, Judge:
The Commissioner determined that petitioner was hable for the excise tax imposed by section 4975(a) in the amount of $7,787.50 for each of the taxable years 1980 and 1981. The issues for decision are: (1) Whether the tax provided in section 4975(a) should be imposed when a prohibited transaction would qua…
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, 2024
…in payment of a “substantial number” of future premiums on such a contract.
(47) Sections 267, 304, 331, 332, 351, and 1502.—Losses, Expenses, and Interest with Respect to Transactions Between Related Taxpayers; Redemption Through Use of Related Corporations; Gain or Loss to Shareholder in Corporate Liquidations; Compl…
IRCCourt RulingsAug 22, 1994related by meaning
years in issue in respect of a reserve for postretiremerit medical and life insurance benefits within the meaning of section 419A(c)(2).
C. Conclusion Based on the foregoing, we hold that petitioner’s account limit under section 419A(c)(l) attributable to claims incurred but unpaid for medical benefits is $3,876,709 an…
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
… that the suggested changes are inconsistent with the general principle in the Act and in 31 CFR 29.331. Section 29.331 provides that all requirements must be satisfied as of June 30, 1997, for service to be creditable towards a Federal Benefit Payment. In turn, the general principle is consistent with section 11012(b)…
IRCCourt RulingsJan 20, 1983related by meaning
sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006
…02(e)(2) business terminations are not subject to this provision.)
(23) Sections 302(b)(4) and (e), 331, 332, and 346(a).—Effects on Recipients of Distributions in Corporate Liquidations.—The tax effect of the liquidation of a corporation preceded or followed by the transfer of all or a part of the business assets to a…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
IRCCourt RulingsFeb 6, 1992related by meaning
e original intent of Congress, as set forth in the legislative history of the statute and its various amendments.
Validity of the Temporary Regulation We have previously held that temporary regulations are entitled to the same weight as final regulations. Nissho Iwai American Corp. v. Commissioner, 89 T.C. 765 (1987); …
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…02(e)(2) business terminations are not subject to this provision.)
(23) Sections 302(b)(4) and (e), 331, 332, and 346(a).—Effects on Recipients of Distributions in Corporate Liquidations.—The tax effect of the liquidation of a corporation preceded or followed by the transfer of all or a part of the business assets to a…
IRCCourt RulingsJun 1, 1987related by meaning
transaction on the first day of each taxable year or portion of a taxable year within the taxable period until corrected on May 10, 1982, was proper. Based on our determinations herein,
Decision will be entered for the respondent.
Unless otherwise indicated, all section references are to the Internal Revenue Code of 1…
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…