IRCCourt RulingsMay 8, 2017
…. Therefore petitioners
are not entitled to a deduction under section 691(c).
In any event, section 461(a) requires a taxpayer to deduct expenses for the
year required under his or her method of accounting. A cash basis taxpayer
generally must deduct his or her expenses for the year that payment of those
expenses takes…
IRCCourt RulingsDec 2, 2013
03, 207-208 (1990); Commissioner v. Tufts, 461 U.S. 300, 307 (1983).
Rather, petitioners were expected to pay back the loans to the insurance company. See Commissioner v. Tufts, 461 U.S. at 307.
Where an insurance policy is terminated and the proceeds are used to satisfy
a loan against the policy, the payment against t…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
IRCCourt RulingsJun 18, 1999related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 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 referenc…
IRCCourt RulingsMay 14, 2009
…,150 payment was attributable to the payment of
qualified residence interest .
Furthermore, section 461(a) provides that deductions "shall
be taken for the taxable year which is .the proper taxable year
under the method of accounting used in computing taxable income ."
Since petitioners are cash method calendar year ta…
IRCCourt RulingsAug 22, 2002
…r the taxable year in which actually made”.
Sec. 1.446-1(c)(1)(i), Income Tax Regs.; see secs. 446, 461; sec.
1.461-1(a)(1), Income Tax Regs. Petitioner’s higher education
expenses for 1998 are limited to the qualified higher education
expenses that she actually paid during 1998. Accordingly, only
$261.47 of petitioner…
IRCCourt RulingsFeb 12, 2014
…ommissioner v. Indianapolis Power & Light Co., 493 U.S. 203, 207-208 (1990);
Commissioner v. Tufts, 461 U.S. 300, 307 (1983), because they were obliged to
repay the loans to Northwestern, see Commissioner v. Tufts, 461 U.S. at 307.
When an insurance policy is terminated and all or part of the proceeds are
used to satis…
IRCCourt RulingsMar 4, 2010
…5 of which was
taxable .
Petitioner made no Federal income tax payments for 2003
apart from the $10,461 his employer withheld from his wages
during the year . On his 2003 Form 1040, U .S . Individual Income
Tax Return, petitioner reported zero wages and $2,735 of taxable
pension and annuity income ; he claimed the stan…
IRCCourt RulingsJan 19, 2010
…nt some constitut
or ;ambiguous language, non
limited to interpreting th
Congress enacted it . Barn 461 '(2002) . _ The Supreme=C
time and again that courts
in a statute what it mean s
there . When the words o
first canon is also the-l a
Id . .at 461-462 (quoting C o
249, 253-254 (1992)-) .
the definition of IRAs .in s…
IRCCourt RulingsJul 24, 2003related by meaning
1
Unless otherwise indicated, section references
hereafter are to the Internal Revenue Code in effect for the year
at issue.
T.C. Summary Opinion 2003-103
UNITED STATES TAX COURT
SANTOS M. AND INGRID I. CASTILLO, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4698-02S. Filed July 24, 2003.
Sant…
IRCCourt RulingsJan 31, 1973
… for the periods that such nonbusiness use applied.
OPINION
1. Workmen's Compensation Issue Section 461, I.K.C. 1954, provides that a deduction allowed under the Code shall be taken for the taxable year which is the proper taxable year under the method of accounting used in computing taxable income. Under an accrual me…
IRCCourt RulingsMay 14, 1974
…axpayer incurs a liability to make the contribution, the amount of which is aecruable under section 461 for such taxable year. See section 461 and the regulations thereunder. There is another exception in the case of certain taxpayers who are required to make additional contributions as a result of the Act of June 15, …
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsSep 29, 1992
…luation Date Boren Steel . 458
Hours of Service Citrus Valley . 460
Old Frontier. 460
Boren Steel . 461
Section 4972 Excise Tax. 461
Section 6651 Failure to File Addition to Tax . 462
Section 6659A Additions to Tax . 463
Conclusions . 465
OPINION
Clapp, Judge:
Respondent determined the following deficiencies in and add…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
86 FR 36872 — Requirements Related to Surprise Billing; Part I IRCFinal Rules (FR)Jul 13, 2021
ly $15,461.[194]
Table 8—One-Time Burden and Cost To Provide Notice of Right To Designate a Primary Care Provider
Year
Estimated number of
respondents Estimated number of
responses
Burden per response
(hours)
Total annual burden (hours)
Total estimated
labor cost
Total estimated
printing and
materials
cost
Total estima…
IRCCourt RulingsSep 18, 1996related by meaning
sents taxable
earnings from petitioner's IRA and that such amount is properly
includable in petitioners' gross income for 1990. Sec.
408(d)(1).
- 25 - In view of our conclusion, supra
, that petitioner's Transfer
Refund qualifies for tax-free rollover treatment in 1989 under
section 402(a)(5)(D), we understand petition…
T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. IRCTreasury DecisionsSep 18, 2006
…me item to a method of accounting utilizing the 31/2 month rule authorized by regulations section 1.461-4(d)(6)(ii) or the recurring item exception authorized by regulations section 1.461-5. Rev. Proc. 2006-12 modified.
EMPLOYEE PLANS
T.D. 9280 T.D. 9280
Final regulations under section 411(d)(6) of the Code provide gui…