IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
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
.
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
…ee relationship
176
.12 Incomplete applications
176
.13 Effect of failure to disclose material fact
177
.14 Where to file requests
177
.15 Submission of related plans
177
.16 Withdrawal of requests
178
.17 Right to status conference
178
.18 How to request status conference
178
.19 Correct format required
178
SECTION 11…
IRCCourt RulingsApr 19, 1989related by meaning
e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014
…,000 by the amount of the AIR ($500,000 − $450,000). The reduced deduction limit is applied to O’s $177,778 attributable to services performed by O in L’s 2018 taxable year that is paid in 2018. Because the $177,778 exceeds the reduced deduction limit of $50,000, $50,000 of DDR is deductible for L’s 2018 taxable year, …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…(or self-pay) individuals fall in this category. Therefore, the annual equivalent cost estimate is $177,256,402.[287]
Thus, a total of $265,884,603 is estimated for business operations specialists, when adding the cost if no additional items and services are needed ($88,628,201) to the cost if additional items and serv…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
IRCCourt RulingsDec 22, 1997
…vant herein, respondent disallowed as excess
contributions for 1987, 1988, and 1989, respectively, $177,505,
$177,760, and $175,454 of the total claimed deductions relating
to the plans.
Also, for 1988, 1989, and 1990, respondent determined that
petitioner was liable for excise taxes under section 4972 with
regard to t…
IRCCourt RulingsDec 8, 1987related by meaning
ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468.
Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
IRCCourt RulingsNov 7, 1996
…utation was as follows:
Taxable distribution $327,814
less: threshold (150,000)
Excess distribution 177,814
On brief, respondent concedes that the excess distribution was
only $177,655.59, i.e., $327,655.59 (the taxable portion of the
Transfer Refund) less $150,000.
that exceeded $150,000 as an excess distribution from…
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 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…
IRCCourt RulingsOct 11, 1957related by meaning
s that its enforcement would amount to a deprivation of property without due process of law as required under the Fifth Amendment to the Constitution. We have carefully considered the decision of the Seventh Circuit in the Kohl case, and its application as a precedent in the problem which confronts us. With all due res…
IRCRegulationsJul 26, 2016
…death × 4 Portion of post-June 1986 investment in the contract allocable to each taxable year of D $177.78 Total computation: Total portion of the investment in the contract allocable to each taxable year of C ($728.60 + $444.40) $1,173.00 Total portion of the investment in the co
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCCourt RulingsJun 7, 1984related by meaning
eived. An exception is provided in § 402(a)(2) for capital gains treatment in specific cases. * * * The exception was always strictly construed. * * * Further expansion of the favored treatment specifically provided in § 402(a)(2) as an exercise of legislative grace is a function for the Congress, not for the Courts. S…
Treas. Reg. § 54.9802-4(f)(1)(xii) — Special Rule Allowing Integration of Health Reimbursement Arrangements (HRAs) and Other Account-Based Group Health Plans with Individual Health Insurance Cover… IRCRegulationsAug 19, 2019
…ch of its 14 hourly employees an HRA on the same terms. Plan Sponsor J reasonably expects to employ 177 employees on the first day of the HRA plan year.
IRCCourt RulingsJul 24, 1984related by meaning
ication. Sec. 7805(b). See also sec. 301.7805-l(b), Proced. & Admin. Regs. We will therefore give full retroactive force and effect to the regulation. The final issue presented concerns the amount of petitioner’s allowable sales tax deduction. Since our decision herein serves to increase petitioner’s taxable income, hi…
IRCProposed Rules (FR)Proposed May 13, 2026
…continuing collections of information in accordance with the Paperwork Reduction Act of 1995 (PRA).[177]
This helps to ensure that the public understands HHS's collection instructions, respondents can provide the requested data in the desired format, reporting burden (time and financial resources) is minimized, collect…