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Go to 9 T.C. 174 (not yet in the library — opens the official source)
98 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  2. Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Dec 30, 2024
    …mination letter 172 .05 Opinion letter 173 .06 Oral advice 173 .07 Nonbank trustee approval letters 174 .08 Compliance statement 174 SECTION 4. ON WHAT ISSUES MAY TAXPAYERS REQUEST WRITTEN ADVICE UNDER THIS PROCEDURE? 174 .01 In general 174 .02 Determination Letters 175 .03 Letter Rulings 175 .04 Voluntary Closing Agre…
  3. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    419A(i) provides that the regulations shall be promulgated by the Secretary as may be necessary to carry out the purposes of sections 419 and 419A. 9 If the intent of Congress on a matter is clear, then the Secretary must give effect to the unambiguously expressed intent of Congress. Chevron U.S.A. Inc. v. Natural Res…
  4. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  5. Treas. Reg. § 1.72-5(b)(7) — Expected return.
    IRCRegulationsJul 26, 2016
    …ve received which is in the same ratio that 4 units bear to 10 units) and would thus have received $174.80 less than the portion of the investment in the contract allocable to each of D's taxable years. In these circumstances, D would be entitled to elect to redetermine the portion of the investment in the contract all…
  6. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  7. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009
    s pass to the grantor . See Estate~of O'Connor v . Commissioner , supra at 174 ; see also Hornberger v . Commissioner , T .C . Memo . 2000-42 n .5 ("A grantor trust is not subject to the income tax . Rather, all of the income and deductions pertaining to a grantor trust must be taken into account by the grantor ."), af…
  8. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  9. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  10. T.C. Memo. 2016-174 — Jay D. Schechter v. Commissioner
    IRCCourt RulingsSep 19, 2016
    RS T.C. Memo. 2016-174 UNITED STATES TAX COURT JAY D. SCHECHTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26978-12. Filed September 19, 2016. Russell D. Stanaland, for petitioner. Christopher J. Richmond, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MORRISON, Judge: The responden…
  11. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]
  12. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    pute.5 3Respondent determined some itemized deductions should be disallowed subject to the sec. 68 limitation and a claimed child tax credit should be disallowed under sec. 151(d). 4The sec. 6662(a) penalties for remaining years 2008, 2009, 2010, 2012, 2013, and 2014 stem solely from the disallowed NOL carried forward …
  13. T.C. Memo. 1999-174 — Chrys L. Udoh v. Commissioner
    IRCCourt RulingsMay 21, 1999
    …in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1999-174 UNITED STATES TAX COURT CHRYS L. UDOH, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 22424-97. Filed May 21, 1999. Chrys L. Udoh, pro se. Lindsey D. Stellwagen , for respondent. MEMORANDUM OP…
  14. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    ibution was not from an IRA, it would not qualify for the exception for higher education expenses, even if it were used for higher education expenses. Petitioners stated in their petition that the distribution was from a section 401(k) account, a fact which petitioners have not denied. Petitioners did not respond to th…
  15. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Either party may move for summary adjudication upon all or any part of the legal issues in controversy. Rule 121(a). Full or partial summary judgment is appropriate where the record shows that there is no genuine issue as to any material fact and that a decisi…
  16. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    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…
  17. T.C. Memo. 2004-130 — Ralf Zacky v. Commissioner
    IRCCourt RulingsMay 27, 2004
    … account of a prohibited transaction. S. Rept. 93-383, at 94-95 (1973), 1974-3 C.B. (Supp.) 80, 173-174. Disqualification penalized employee/plan participants in that they were denied favorable tax consequences such as deferral of taxation. Id. at 94, 1974-3 C.B. (Supp.) at 173. The goal of Congress in enacting section…
  18. 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
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  19. 44 T.C. 178 — Funkhouser v. Commissioner
    IRCCourt RulingsMay 13, 1965
    …e distribution of such contracts upon any termination of employment. On January 5, 1959, there were 174 employees of the Funkhouser Co. under the age of 65 for whose benefit annuity contracts were held under the Funkhouser Co. pension trust agreement, as amended to include the pension trust agreement of B. J. Funkhouse…
  20. PBGCRegulationsJan 1, 2017related by meaning
    [Reserved]