IRCProposed Rules (FR)Proposed Dec 23, 2025
…ice and for each plan, insurance policy, or coverage included in an aggregated Allowed Amount File.[154]
The Departments finalized this requirement in the 2020 final rules because if the threshold were applied to the aggregated claims data at the service provider level, rather than for each plan or coverage as is requi…
Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division… IRCRevenue ProceduresJan 2, 2018
…O REVENUE PROCEDURE 2017–4?
153
.01 In general
153
.02 Changes related to pre-approved plan program
154
.03 Changes to fees for EP VCP Submissions
154
.04 Changes to other fees
155
.05 Other changes
155
PART I. GENERALLY APPLICABLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGRE…
IRCCourt RulingsFeb 21, 2012related by meaning
Respondent prepared decisiori.documents reflecting respolident's
concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and .
sanctions against respondent based on "reckless professional behavior."
Petitioner is frustr…
Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl… IRCRevenue RulingsMar 8, 2004
Rul. 66-110, as amplified by Rev. Rul. 67-154, for periods after December 31, 2003, with respect to arrangements entered into after January 28, 2002. Rev. Rul. 2003-105, 2003-40 I.R.B. 696, obsoleted Rev. Rul. 66-110 for arrangements entered into after September 17, 2003, except as provided in paragraph 3 of Section I…
68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977related by meaning
r, 68 T.C. 826 (1977).
In view of concessions made by the parties and our conclusions on the disputed issues,
Decision will be entered under Rule 155. All statutory references are to the Internal Revenue Code of 1954, as amended, unless otherwise indicated.
Variances between this schedule and Form 4848 reflect persons …
IRCCourt RulingsSep 24, 2026
…
Examination Division ’ s determination to assert a penalty. See Belair
Woods, LLC v. Commissioner, 154 T.C. 1, 15 (2020) .
Petitioner does not dispute that the IRS met these requirements
here. The IRS secured managerial approval of the penalty on May 20 ,
202 4, when the revenue agent’s manager noted in the examinatio…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…e the vesting protections applicable to the
VTTM. See Concerned Dublin Citizens v. City of Dublin , 154 Cal. Rptr.
3d 682, 698 (Ct. App. 2013) (holding that new threshold requirements
for greenhouse gases were not new information requiring a
supplemental environmental impact report because the potential
environmental i…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…tate law. See Belk v.
Commissioner, 140 T.C. 1, 13 n.21 (2013) , supplemented by T . C. Memo.
2013- 154, aff’d , 774 F.3d 221 (4th Cir. 2014). In Alabama judicial review
of an unambiguous contract is limited to the four corners of the
document. See Lafayette Land Acquisitions II, LLC v. Walls, 385 So. 3d
519, 522– 23 (…
IRCCourt RulingsAug 30, 1993related by meaning
ing plan. Held, such transfer is an employer reversion subject to the 10-percent excise tax under sec. 4980, I.R.C.
Robert L. Raymond, for petitioner. P. Joseph Ineich, for respondent.
*54 Hamblen, Chief Judge.
HAMBLEN
*189 OPINION
Hamblen, Chief Judge: This case was assigned to Special Trial Judge Francis J. Cantrel p…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
tment. Sec. 452 (b) (2); sec. 40.452-1, Regs. 130. Here, the petitioner has not maintained an inconsistent position within the meaning of section 452. It does not insist that the deduction for officers’ compensation in the fiscal year 1941 was improperly claimed. It does not maintain that any portion of such compensati…
IRCCourt RulingsMar 31, 2008
… circumstances . Geftman v . Commissioner ,
T .C . Memo . 1996-447, revd . in part on other grounds 154 F .3d 61
(3d Cir . 1998)
. The ultimate question remains whether "there
[was] a genuine intention to create a debt, with a reasonable
IRCCourt RulingsMar 31, 1997related by meaning
1
All section references are to the Internal Revenue Code
as amended, unless otherwise indicated. All Rule references are
to the Tax Court Rules of Practice and Procedure.
T.C. Memo. 1997-159
UNITED STATES TAX COURT
ROBERT CHARLES FOHRMEISTER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11748…
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 RulingsJul 22, 1980related by meaning
t acquire a beneficial ownership interest in the ETS trust contributions in 1974.
Because of a concession by respondent with respect to the year 1973, Decision will be entered under Rule 155.
Reviewed by the Court.
Unless otherwise indicated, all statutory references are to the Internal Revenue Code of 1954 as amended …
IRCCourt RulingsOct 8, 2003
… F.3d 1435, 1439-1442 (Fed. Cir. 1996), and
Truck & Equip. Corp. v. Commissioner
, 98 T.C. 141, 145-154
(1992). We stress that the House Committee on Ways and Means, in
describing a 1984 amendment to sec. 404(b), stated that:
Generally, all compensation arrangements which defer
receipt of compensation by the employee o…
IRCPrivate Letter RulingsDec 20, 2013
…d States , 173 Ct. Cl. 139, 351 F.2d 619 (1965); and Estate of
S cofield v. Commissioner , 266 F.2d 154, 159 (6th Cir. 1959), revg. 25 T.C. 774 (1956).
CONCLUSION:
PLR - 113782-13 11
Taxpayer is allowed a loss under section 165 relating to the to the surrender of
BOLI Policies 1, 2, and 3, with the amount of such loss …
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
ERISACourt RulingsAug 14, 2026
…p’x at 152–53. He was “present for all of the negotiations up through the ’93 negotiations.” Id. at 154. Porter
affirmed, under oath, that during the 1993 negotiations, he
“believe[d] the state of the law was we couldn’t touch” the
healthcare benefits of a former employee who had retired
prior to the 1993 negotiations. As…
IRCCourt RulingsMar 9, 2011related by meaning
4 (1984); see United
States v. Mead Corp., 533 U.S. 218 (2001). Although they may be
entitled to deference under Skidmore v. Swift & Co., 323 U.S. 134 (1944), see United States v. Mead Corp., supra, we need not
decide whether Notice 2004-8, supra, should be given Skidmore
deference because the Transaction does not féll…