30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
IRCCourt RulingsOct 9, 1997related by meaning
ent with the intent of
DEFRA, and because it permissibly fills a gap created by sections
419 and 419A, we conclude that section 1.419-1T, Q&A-5(b)(1), Temporary Income Tax Regs., 51 Fed. Reg. 4324 (Feb. 4, 1986), is
not impermissibly broader than sections 419 and 419A and,
accordingly, we hold that it is valid. Chevron…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
IRCCourt RulingsJan 14, 2013
…e estimated amount for the years his
tax statements stated that he worked 25% of his time at TORCH, 100% for the years
after his retirement, and 25% for the years after the Fletchers sold TORCH. The
following table shows Dr. Newlon's conclusions as to reasonable compensation for
the Fletchers:
[*16] Year Ms. Fletcher %…
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 …
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
ragraphs (k)(2)(i)(A)-(B) of this section.
(v) The amount includible in B’s gross income for the $100,000 of excess group-term life insurance is $120. Example 2. Excess group-term life insurance coverage provided through salary reduction in a cafeteria plan where employee purchases a portion of group-term life insuranc…
IRCRegulationsMay 18, 2016
the 100 shares of stock in ABC Corp. are worth $50,000 and the 100 shares of stock in XYZ Corp. are also worth $50,000. Taxpayer B decides that she would like to recharacterize the ABC Corp. shares back to a traditional IRA. However, B may choose only by dollar amount the contribution or portion thereof that is to be r…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCRegulationsJan 19, 2017
…ample 1.On June 1, 2004, the X Corporation grants to E, an employee, a statutory option to purchase 100 shares of X Corporation stock at $100 per share, the fair market value of X Corporation stock on that date. On June 1, 2005, while employed by X Corporation, E exercises the option in full and pays X Corporation $10,…
IRCCourt RulingsJan 20, 1983related by meaning
sue in this case is within the scope of respondent’s authority and is reasonable, it is not necessary to classify it as legislative or interpretative. Respondent’s position is that the disputed regulation appropriately implements section 415, which was intended by Congress to allow automatic increases in benefits based…
89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit IRCFinal Rules (FR)Dec 11, 2024
…. M1 has net unrecognized section 987 gain with respect to M1 QBU. M1 QBU sells property to M2 for €100 in year 1.
(B)
Analysis
—(
1)
In general. Under paragraph (j)(9) of this section, the sale of property is treated as a transfer of the property from M1 QBU to M1, followed by an exchange of the property for €100 dire…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…
82 FR 7336 — Proposed Best Interest Contract Exemption for Insurance Intermediaries ERISAProposed Rules (FR)Proposed Jan 19, 2017
…t BD
2
3
2
2
3
5
13
12
Career Agents
6
6
6
5
6
4
5
6
Full Service National BD
0
0
0
0
1
1
2
3
Total
100
100
100
100
100
100
100
100
Source:
LIMRA Individual Annuity Yearbook 2008-2015.
( printed page 7355)
Role of IMOs in Distributing Insurance Products and Market Structure
As discussed earlier in this preamble, the m…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
IRCCourt RulingsApr 18, 1984
…other situation.
30-Percent Tax Bracket
Major A Major B
Without E With E Readjustment pay - year 1 $100.00 o o
Less tax due (30.00) CO o
Net received - year 1 70.00 70
Retirement pay - year 2 100.00 100 $100
Less repayment of readjustment pay (75.00) (75)
Less tax due (7.50) (30) (30)
Net received - year 2 17.50 (5) 70…
64 T.C. 1011 — Catawba Industrial Rubber Co. v. Commissioner IRCCourt RulingsSep 9, 1975related by meaning
rough with the plan, it could doubtless have met and resolved to abandon it, without subjecting petitioner to liability to anyone. [19 T.C. at 26-27.] See also Precision Industries, Inc., 64 T.C. 901 (1975), recently decided by this Court.
Decision will be entered for the respondent
All section references are to the In…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
1 per 100,000 persons [259]
and the 2020 Agency for Healthcare Research and Quality youth suicide fatality rate of approximately 6.3 per 100,000,[260] and applying these rates to the numbers of individuals 12 years old and older with private health insurance,[261]
suggests approximately 22,200 suicide deaths annually f…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsOct 3, 1995related by meaning
distribution qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as p…
IRCRegulationsMay 18, 2016
rustee X's taxable year ending in 1995 is $500,000 per account (no more than $100,000 of which is permitted to be cash). Thus, the dollar limit that would apply to IRA-1 is $500,000; the dollar limit for IRA-2 is $400,000 ($100,000 of the cash and the $300,000 of the value of the securities); the dollar limit for IRA-3…