IRCRegulationsDec 30, 2016
(a)(12) (12) Dependent. The term dependent means a child (as defined in section 152(f)(1) but excluding a stepson, stepdaughter or an eligible foster child (and excluding any individual who is excluded from the definition of dependent under section 152 by operation of section 152(b)(3))) of an employee who has not atta…
IRCPrivate Letter RulingsAug 23, 2024
…l care (as
defined in section 213(d)) of the taxpayer, spouse, or dependents (as defined in section
152, determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof) and
any child (as defined in section 152(f)(1)) who has not attained age 27 as of the end of
the taxable year.
Treas. Reg § 1.105-2 pro…
80 FR 72192 — Final Rules for Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, Dependent Coverage, Appeals, and Patient Protec… IRCFinal Rules (FR)Nov 18, 2015
…esidency, or other dependency factors for individuals under age 26 who are not described in section 152(f)(1) of the Code. For an individual not described in section 152(f)(1), such as a grandchild or niece, a plan may impose additional conditions on eligibility for health coverage, such as a condition that the individ…
IRCPrivate Letter RulingsJun 5, 2020
…ed in section 213(d)) of the taxpayer or the taxpayer’s spouse or dependents (as defined in section 152, determined with out regard to subsections (b)(1), (b)(2), and
(d)(1)(B)) and any child (as defined in section 152(f)(1)) who has not attained age 27 as
of the end of the taxable year. Section 1.105-2 provides that o…
T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b… IRCTreasury DecisionsDec 7, 2015
…esidency, or other dependency factors for individuals under age 26 who are not described in section 152(f)(1) of the Code. For an individual not described in section 152(f)(1), such as a grandchild or niece, a plan may impose additional conditions on eligibility for health coverage, such as a condition that the individ…
IRCCourt RulingsOct 12, 1978related by meaning
do not deal with the operations of the plan, there is a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comm…
IRCCourt RulingsDec 11, 2003related by meaning
ining whether petitioner satisfies the return-filed safe
harbor of section 6654(d)(1)(B)(i).
Because petitioner made no estimated tax payments for the audit year, he necessarily failed the alternative safe harbor of
section 6654(d)(1)(B)(i) to make estimated tax payments equal to
“90 percent of the tax” (i.e., his ulti…
IRCPrivate Letter RulingsMar 11, 2016
…e (as defined in
section 213(d)) of the taxpayer, his spouse, his dependents (as defined in section 152,
determined without regard to subsections (b)(1), (b)(2), and (d)(1)(B) thereof), and any
PLR - 121608-15 6
child (as defined in section 152(f)(1) ) of the taxpayer who as of the end of the taxable
year has not attai…
IRCCourt RulingsAug 12, 1998related by meaning
titioner, WE 7, and
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4
The complaint filed in the Superior Court indicates that
the subject matter of the case involved a contract to purchase a portion of a shopping center entered into on Aug. 3, 1987.
the Guardian Construction Co., Inc., as corporate partners of
Estes Co. Petitioner was identified as a partner…
IRCCourt RulingsMar 9, 2011
… to both
the deemed and actual distributions. For 2004 to 2006
ENH reported dividend income of $100,152, $99,916, and
$80,510 and paid Federal income taxes of $22,063,
$21,943, and $15,349,v respectively. TDH reported
dividend income of $100,152, $99,916, and $80,510 and
paid Federal income taxes of $22,063, $21,943, a…
IRCCourt RulingsJan 31, 2001
…may deduct the exemption amount with respect to such child
for the year. See sec. 151(e). Section 1.152-4(b), Income Tax
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5 Sec. 152(e)(2) provides a means by which the custodial
parent may permit the noncustodial parent to claim the child as a
dependent for the year. However, petitioner does not claim that
Ms. H…
IRCCourt RulingsMay 23, 2005related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2001,
the taxable year in issue. All monetary amounts are rounded to
the nearest dollar.
T.C. Summary Opinion 2005-62
UNITED STATES TAX COURT
THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v
.
COMMISS…
IRCRegulationsJul 26, 2016
…2.5 2.3 2.2 111 3.8 3.5 3.3 3.2 3.0 2.8 2.6 2.4 2.3 2.1 112 3.7 3.5 3.3 3.1 2.9 2.8 2.6 2.4 2.2 2.1 113 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.4 2.2 2.0 114 3.7 3.5 3.3 3.1 2.9 2.7 2.5 2.3 2.1 2.0 115 3.7 3.4 3.2 3.0 2.8 2.7 2.5 2.3 2.1 1.9 Table VI—Ordinary Joint Life and Last Survivor Annuities; Two Lives—Expected Return Mult…
IRCCourt RulingsSep 28, 2022related by meaning
. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant
summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of
law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994).…
IRCCourt RulingsFeb 15, 2002
spouse, or a dependent (as
defined in section 152)”. While petitioner’s mother could have
been his dependent, see sec. 152(a)(4), in order for her to qualify as his dependent, petitioner would have had to provide
over half of her support, sec. 152(a). We note that not only is
the record totally devoid of any evidence …
IRCCourt RulingsJun 4, 2014related by meaning
hey would establish that respondent proceeded against the targets using
information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's
award determination.
We hold, consistent with the rationale of Dacosta, that this Court…
IRCCourt RulingsSep 21, 2017
ependent (as defined in section 152) of the taxpayer for the taxable
year." Sec. 151(c). Section 152(a) defines a "dependent" to include a "qualifying child". Generally, a "qualifying child" must: (1) bear a specified relationship to
the taxpayer; (2) have the same principal place of abode as the taxpayer for more
than…
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
IRCCourt RulingsMar 25, 2013
…poration has a limited number of officers. Charles Schneider &
Co. v. Commissioner, 500 F.2d at 151-152. No single factor is dispositive. See Pepsi-Cola Bottling Co. v. Commissioner, 528 F.2d 176, 178 (10th Cir. 1975),
aff'g 61 T.C. 564 (1974). Special scrutiny is given in situations where a
corporation is controlled b…
IRCCourt RulingsDec 16, 1998
…termined it was, and, relying primarily
on Commissioner v. Keystone Consol. Indus., Inc.
, 508 U.S. 152
(1993), argues to the same effect in this proceeding.
Petitioner argues that the transfer was not a prohibited
- 7 -
transaction under section 4975(a). According to petitioner,
the prohibited transaction rules do not…