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61 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
  2. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024
    … “qualified taxpayer” means — (A) any individual whose principal residence (for purposes of section 1033(h)(4)) is located in a disaster area, (B) any taxpayer if the taxpayer’s principal place of business (other than the business of performing services as an employee) is located in a disaster area, 8
  3. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    …13 See, e.g., In re Hatton , 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang , 164 F.3d 1029, 1033 (6th Cir. 1999). section 6653(a), 3 section 6662, 4 section 6013, 5 section 6033, 6 section 6651(f), 7 section 6511, 8 section 6011, 9 section 6012, 10 section 6072, 11 and former section 6661, 12 among others. Othe…
  4. T.C. Memo. 1998-399 — Ronny H. & Charlotte A. Schmalzer v. Commissioner
    IRCCourt RulingsNov 10, 1998related by meaning
    tstanding rollover involved in this case. Accordingly, the amount of excludable basis in the instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is $1,950 and the denominator of which is $1,374.53 plus $6,100, resulting in an amount excludable of $1,591.40.…
  5. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    efinition of an applicable foreign legal restriction and the taxpayer has elected the deferred income method of accounting, any section 482 allocation connected with the transaction will be defer rable until the restriction is removed. Deductions and credits chargeable against a deferred amount are subject to deferral …
  6. Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in …
    IRCRevenue RulingsDec 28, 2009related by meaning
    ment 2009-88 Announcement 2009-88 A list is provided of organizations now classified as private foundations. Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
  7. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984related by meaning
    ue Act of 1978), 1978-3 C.B. (Vol. 1) 521, 626; Staff of the Joint Comm, on Taxation, General Explanation of the Revenue Act of 1978, at 103, 106-107. However, even if a taxpayer qualifies for such relief, nothing in the statute or the legislative history authorizes relief from the section 4973 tax for the years during…
  8. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    5). 28See, e.g., Priv. Ltr. Rul. 201535029 (Aug. 28, 2015) (waiver granted to taxpayer suffering from "mild cognitive impairment and moderate clinical depression", who was "not aware that he did not roll over Amount 1 to another IRA until his tax return for 2013 was being prepared"); Priv. Ltr. Rul. 201323044 (June 7, …
  9. I.R.C. § 501(c)(12)(F) — Exemption from tax on corporations, certain trusts, etc.
    IRCCode / StatuteJan 24, 2020
    …tive electric company, the gain from which qualifies for deferred recognition under section 1031 or 1033, but only if the replacement property acquired by such company pursuant to such section constitutes property which is used, or to be used, for—
  10. 103 T.C. 200; 103 T.C. No. 13 — Rubin v. Commissioner
    IRCCourt RulingsAug 15, 1994
    …mployee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, 88 Stat. 914. ERISA section 1033(a), 88 Stat. 947, also added section 6059 to the Code. Section 6059 requires employers and plan administrators to engage an enrolled actuary to prepare and certify an actuarial report (Schedule B) for the pension pl…
  11. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    er for calendar year 1993 except that the reference to "20% reduction" was changed to "50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA 1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this connection, prior to its amendment by OBRA …
  12. 89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCFinal Rules (FR)Sep 23, 2024
    … of the ICD for diagnosis and procedure coding. Back to Citation 54.  Public Law 114-255, 130 Stat. 1033 (Dec. 13, 2016). Section 13007 of the Cures Act states that, if a plan or an issuer offering group or individual health insurance coverage provides coverage for eating disorder benefits, including residential treatm…
  13. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
  14. 88 FR 51552 — Requirements Related to the Mental Health Parity and Addiction Equity Act
    IRCProposed Rules (FR)Proposed Aug 3, 2023
    …il 2021. See section 13003 of the 21st Century Cures Act (Cures Act), Public Law 114-255, 130 Stat. 1033 (Dec. 13, 2016), as amended by the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities Act, Public Law 115-271, 132 Stat. 3894 (Oct. 24, 2018). Back to Citation…
  15. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
  16. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
  17. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    section 1041. See Balding v. Commissioner, 98 T.C. 368 (1992). In order to implement the views expressed herein, An appropriate order will be issued. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules o…
  18. 85 T.C. 1024; 85 T.C. No. 59 — Greene v. Commissioner
    IRCCourt RulingsDec 24, 1985related by meaning
    terms of section 1035, and that no gain or loss should be recognized to petitioner by reason of the exchange. Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954 as in effect in the year in issue, and all Rule references are to the Tax Court Rules of Practice and P…
  19. 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
    s in order to comply with their FATCA obligations, unless the FFIs qualify for an exemption under the FATCA regulations. Notice 2016–48 Notice 2016–48 This Notice explains how the IRS will implement the changes to the Individual Taxpayer Identification Number (ITIN) program resulting from the enactment of the Protectin…
  20. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…