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…
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…
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
.
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 …
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…
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 …
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…
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…
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…
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…
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…
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…
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…
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…
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 …
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…
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)…
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…
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…
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…