IRCCourt RulingsJan 17, 2024related by meaning
ies.
Subchapter C, consisting solely of section 6751, sets forth “Procedural
Requirements” applicable to all of the foregoing items. The fact that the exaction at issue does not appear in C hapter 68 of the Code provides
evidence that it is not a “penalty” to which the “procedural requirements” of section 6751(b) apply…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024related by meaning
is obtained on or before the date the IRS issues a notice of
deficiency.”), aff’ g in part, rev’g in part and remanding T.C. Memo. 2020-99; Kroner v. Commissioner, 48 F.4th 1272, 1276– 81 (11th Cir. 2022), rev’g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74
…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016related by meaning
note, Pub. L. 114-74 at § 701. Subparts H and I issued under 8 U.S.C. 1101(a)(15)(H)(i)(b) and (b1), 1182(n), 1182(t), and 1184; 29 U.S.C. 49
et seq.; sec 303(a)(8), Pub. L. 102-232, 105 Stat. 1733, 1748 (8 U.S.C. 1182 note); and Title IV, Pub. L. 105-277, 112 Stat. 2681; and 28 U.S.C. 2461 note, Pub. L. 114-74 at § 70…
Joint BoardRegulationsDec 30, 2016related by meaning
(a)(9) (9) Directly or indirectly attempting to influence, or offering or agreeing to attempt to influence, the official action of any officer or employee of the Internal Revenue Service by the use of threats, false accusations, duress or coercion, by the offer of any special inducement or promise of an advantage, or b…
IRCCode / StatuteJan 5, 2023related by meaning
(d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and
(d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer.
(d)(2)(C) (C) Reduction not to apply to tax shelters
(d)(…
89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction IRCProposed Rules (FR)Proposed Mar 25, 2024related by meaning
and knows or has reason to know that the transaction is a prohibited tax shelter transaction. This liability is not joint and several.
C. Disclosures Section 53.6011-1 requires that a tax-exempt entity subject to the section 4965 excise tax must file Form 4720,
Return of Excise Taxes Under Chapters 41 and 42 of the In…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
87 FR 50240 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations IRCFinal Rules (FR)Aug 16, 2022related by meaning
organizations (in the case of charitable organizations and applicants), and the head of the State agency designated by the State
( printed page 50242) attorney general as having the primary responsibility for overseeing the solicitation of funds for charitable purposes (in the case of section 501(c) organizations other…
83 FR 36417 — Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions IRCFinal Rules (FR)Jul 30, 2018
…acknowledgment under section 170(f)(12)(B)(iii) is provided; and
(iv) Property described in section 1221(a)(1) (inventory and property held by the donor primarily for sale to customers in the ordinary course of the donor's trade or business).
(3)
Completed Form 8283 (Section B).
90 FR 39320 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Aug 15, 2025related by meaning
RT 4065—ANNUAL REPORT
26. The authority citation for part 4065 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3), 1365.
§ 4065.3
[Amended] 27. Amend § 4065.3 by removing “(Approved by the Office of Management and Budget under control number 1212-0026)”.
PART 4203—EXTENSION OF SPECIAL WITHDRAWAL LIABILITY RU…
88 FR 75979 — Proposed Amendment to Prohibited Transaction Exemption 2020-02 ERISAProposed Rules (FR)Proposed Nov 3, 2023related by meaning
y crime, however denominated by the laws of the relevant foreign or state government, that is substantially equivalent to an offense described in (A). For purposes of this section (a)(1), a person shall be deemed to have been convicted of a crime as of the “conviction date,” which is the date of the judgment of the tri…
75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Jun 16, 2010related by meaning
ly published, direct contact with taxpayers known to have participated in a tax shelter promotion.
(B)
Taxpayer acting in good faith
—(
1)
In general. The IRS may suspend interest relating to a listed transaction or an undisclosed reportable transaction accruing on or before October 3, 2004, if the taxpayer has acted r…
T.D. 9836 — These final regulations provide guidance regarding substantiation and reporting requirements for cash and noncash charitable contributions. The final regulatio… IRCTreasury DecisionsAug 13, 2018
…acknowledgment under section 170(f)(12)(B)(iii) is provided; and
(iv) Property described in section 1221(a)(1) (inventory and property held by the donor primarily for sale to customers in the ordinary course of the donor’s trade or business).
(3) Completed Form 8283 (Section B). A completed Form 8283 (Section B) includ…
91 FR 42353 — Charitable Remainder Annuity Trust Listed Transaction IRCFinal Rules (FR)Jul 9, 2026related by meaning
f the Office of Associate Chief Counsel (Passthroughs, Trusts & Estates) (202) 317-5279 (not a toll-free number).
SUPPLEMENTARY INFORMATION:
Authority This document amends the Income Tax Regulations (26 CFR part 1) by adding final regulations under section 6011 of the Internal Revenue Code (Code) to identify certain CR…
IRCCourt RulingsFeb 4, 1998
…nition
of that gain, it is fully includable in his gross income for
1993. See secs. 61(a)(3), 1034, 1221.
5
See secs. 72, 402(a), 408(d)(1).
property,
4
and distributions from qualified retirement plans
5
were includable in petitioner's gross income for the years in
issue, and that the distributions from qualified reti…
IRCCourt RulingsDec 13, 2012
…particular year and specif[ies] the amount of the deficiency.'"
Stoecklin v. Commissioner, 865 F.2d 1221, 1224 (1 lth Cir. 1989) (quoting Benzvi
v. Commissioner, 787 F.2d at 1542), aff'g T.C. Memo. 1987-453.
Petitioner, through counsel, makes two main arguments. First, he cites Scar
v. Commissioner, 814 F.2d 1363 (9th …
IRCCourt RulingsOct 30, 2014
…preferential tax treatment of long-term capital gain if certain conditions are met.
See secs. 1(h), 1221(a)(1), 1222(3). Petitioner's aim throughout the merger was to
reduce his tax liability by structuring the $3,027,515 he would receive as deriving
purely from a stock sale and deserving of preferential tax treatment.…
IRCCourt RulingsFeb 14, 1996
…at the form of their
agreement purports to do. Grodt & McKay Realty, Inc. v.
Commissioner
, 77 T.C. 1221, 1237 (1981).
The term "sale" is given its ordinary meaning for Federal
income tax purposes and is generally defined as a transfer of
property for money or a promise to pay money. Commissioner v.
Brown
, 380 U.S. 56…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsMay 27, 2010
…in from the
sale or exchange of property and is long-term capital gain to
Mogelefsky . . See secs . 1221 and 1222 .
Petitioners argue that the 2003 contribution should not be
included . in Mogelefsky's 2003 income because the distribution
occurred in 2002 . Respondent argues that Mogelefsky received the
distribution in…