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43 documents · 0.73sAllIRCERISAPBGCJoint Board
  1. 24 T.C. 460 — Northwest Automatic Products Corp. v. United States
    IRCCourt RulingsJun 23, 1955related by meaning
    h respect to this matter is hereby set for_ at_if that time is not convenient, kindly advise us promptly in order that a continuance may- be arranged. This notice, sent by registered mail, constitutes commencement of the renegotiation proceedings in conformity with the provisions of subsection (c) (1) of the Renegotiat…
  2. T.D. 9169 — Final regulations provide guidance for certain retirement plans containing cash or deferred arrangements under section 401(k) of the Code, and provide for matc…
    IRCTreasury DecisionsJan 31, 2005related by meaning
    INCOME TAX Rev. Rul. 2005-5 Rev. Rul. 2005-5 LIFO; price indexes; department stores. The November 2004 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 refere…
  3. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997related by meaning
    he penalties in docket Nos. 2545-94 and 9230-94; an appropriate decision for respondent will be entered in docket No. 5754-94 as to the deficiency and the addition to tax under section 6651(a)(1) and for petitioner with respect to the penalty .
  4. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998related by meaning
    over its proceeds, including accrued interest, into CD No. 11813-17572 in the amount of $249,683.99 issued by TC; this CD was pledged as collateral on Loan No. 1310001 on October 15, 1987.10 Ex. C10 & C11. On October 19, 1987, CD No. 11813-17493 matured, and Respondents rolled its proceeds over into CD No. 11813-17579 …
  5. T.D. 9459 — Final regulations under sections 401(a)(9) and 403(b) of the Code permit a governmental plan to comply with the required minimum distribution rules by using a …
    IRCTreasury DecisionsOct 13, 2009related by meaning
    ertain businesses and will reduce the number of information returns for cancellation of indebtedness required to be filed. REG-136563-07 REG-136563-07 Proposed regulations under section 6011 of the Code provide rules requiring the disclosure of listed transactions and transactions of interest with respect to the genera…
  6. 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 …
  7. T.D. 9294 — Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recip…
    IRCTreasury DecisionsNov 27, 2006related by meaning
    T.D. 9294 Use of Electronic Media for Providing Employee Benefit Notices and Making Employee Benefit Elections and Consents DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1, 35, and 54 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulation. SUMMARY: This document contains final reg…
  8. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    but before the due dates of the returns as extended. 1. Held : pension contributions, based on units of service worked after the close of TYE 8801 and before Oct. 17, 1988, were not on account of P's TYE 8801, as required by sec. 404(a)(6), I.R.C., and are therefore not deductible in that year. Lucky Stores, Inc., & Su…
  9. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    payer has declined to sign a consent to extend the period; or (2) when such notification would be prejudicial to the best interests of the Government. If the taxpayer does not agree that the request for a TAM should be withdrawn, the procedures in section 12 of this revenue procedure must be followed. EP or EO Technica…
  10. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    payer has declined to sign a consent to extend the period; or (2) when such notification would be prejudicial to the best interests of the Government. If the taxpayer does not agree that the request for a TAM should be withdrawn, the procedures in section 12 of this revenue procedure must be followed. EP or EO Technica…
  11. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    ice transactions and have been identified by notice, regulation, or other formeof ,published guidance . . Sec . 1. 6011-4 (b) (2) , Income- Tax Regs . asAccording to the letters, the change was made effective, retroactively to Jan 1, 2004. However, we treat the change as actually occurring ori-Nova. 17 2004, as this ai…
  12. Notice 2024-16 — Guidance Related to Section 961 and Certain Inbound Nonrecognition Transactions
    IRCNoticesJan 29, 2024related by meaning
    3 of this notice should apply to transactions other than covered inbound transactions and whether additional limitations should apply in those cases. Comments should be submitted by February 26, 2024. Comments may be submitted electronically via the Federal eRulemaking Portal at www.regulations.gov (type IRS-2024-16 i…
  13. 72 T.C. 117 — Dallas Dental Lab, Inc. v. Commissioner
    IRCCourt RulingsApr 12, 1979related by meaning
    OPINION Tannenwald, Judge: Respondent determined deficiencies in petitioner’s income tax as follows: TYE June 30— Deficiency 1972 . $197.72 1973 . 1,140.92 1974 . 717.26 The issue for decision is whether compensation paid to employees whose employment terminated before the end of the taxable year is includable in deter…
  14. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM January 07, 2004 Number: 200424004 Release Date: 6/11/04 Third Party Contact: Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04 CASE-MIS No.: TAM- 127815-03, CC:ITA:B07 Industry Director ------------------------------------------------ Taxpayer's Name…
  15. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  16. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  17. T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover …
    IRCTreasury DecisionsMar 23, 2009related by meaning
    aragraph (a)(5)(vi). 2. Revising paragraphs (b)(2)(iv)(A) and (b)(2)(iv)(D). 3. Removing paragraph (b)(2)(iv)(E). 4. Revising paragraph (b)(2)(vi)(A). 5. Revising the heading and adding a new first sentence to paragraph (b)(2)(vi)(B). 6. Removing Examples 3, 4, and 5 of paragraph (b)(2)(viii). 7. Revising paragraph (b)…
  18. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    DISC commissions to ADF International on ADF's qualified export sales (ADF commission payments). ADF reported qualified export sales of $10,308,552 in 2004, $8,325,792 in 2005, and.$7,365,851 in 2006. ADF -5International reported for those years DISC commissions of $465,392, $334,315, and $297,052 and taxable income of…
  19. T.C. Memo. 2006-72 — Stephen Daryl Royal v. Commissioner
    IRCCourt RulingsApr 11, 2006related by meaning
    ecause you forfeited your right to repay the loan in full, effective 09/16/02, a taxable distribution in the amount of $15,462.60 has been declared in connection with the unpaid principal and unpaid interest to 09/16/02, on * * * [petitioner's $15,462.60] loan. Both September 23, 2002 letters further advised petitioner…
  20. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    oration's taxable year was a fiscal year ending June 30 for taxable years ending June 30, 1986 and 1987. During 1987, however, the corporation changed its taxable year to a calendar year. During the relevant taxable years, petitioner was an orthodontist who maintained, through the corporation, an orthodontic practice w…