IRCCourt RulingsJul 13, 2010
…rty for more
than a year, the gain qualifies for long-term capital gain
treatment pursuant to sec . 1222(3)
12 -
and received commissions and fees for her activities as a real
estate broker . She further testified that she .deposited those
commissions and fees into her various business accounts .
Bank deposits are prim…
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…
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…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
PBGCFinal Rules (FR)Nov 5, 2010related by meaning
ent of salary offset, but not other collection procedures;
(iii) The name and address of the office to which the request for a hearing should be sent; (iv) That PBGC will refer the debt to the debtor's employing agency or to the Financial Management Service to implement salary offset, unless the employee files a timely…
89 FR 12955 — Management of Federal Agency Disbursements IRCFinal Rules (FR)Feb 21, 2024related by meaning
l.treasury.gov,
or Rebecca Saltiel, Senior Counsel, at (202) 874-6648 or
Rebecca.Saltiel@fiscal.treasury.gov.
SUPPLEMENTARY INFORMATION:
I. Background In 1998, Fiscal Service issued a final rule, codified at 31 CFR part 208 (part 208), to implement the requirements of 31 U.S.C. 3332, as amended by section 31001(x)(1) o…
IRCCourt RulingsOct 10, 1979
…ncome allocable to corpus. Cf. Barber v. United States, an unreported case (N.D. Ala. 1956, 52 AFTR 1222, 57-1 USTC par. 9377), affd. 251 F.2d 436 (5th Cir. 1958). Compare Edgar v. Commissioner, 56 T.C.
IRCCourt RulingsOct 30, 2014
… 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. In general,…
IRCCourt RulingsMay 27, 2010
…he
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 early 20…
IRCCourt RulingsAug 31, 1964
…the exchange of a capital asset held for more than 6 months is long-term capital gain under section 1222 (3).
This argument is similar to the contention which has been rejected in numerous cases that the gain realized upon the sale of an endowment or annuity policy shortly before its maturity date is long-term capital …
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
URE AND ADMINISTRATION
Paragraph 1.
The authority citation for part 301 continues to read in part as follows:
Authority:
26 U.S.C. 7805 * * *.
Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows:
§ 301.6404-0
Table of Contents.
* * * * *
§ 301.6404-4 Suspension of interest and c…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, the following shall apply in lieu of § 18.9 of this title.
Joint BoardRegulationsOct 18, 2016related by meaning
(f)(1)(iii) (iii) Willfully failing to make a Federal tax return in violation of the revenue laws of the United States, or evading, attempting to evade, or participating in any way in evading or attempting to evade any federal tax or payment thereof, knowingly counseling or suggesting to a client or prospective client …
ERISARegulationsApr 8, 2024related by meaning
(f)(11)(i)(E) (E) Any felony or conspiracy involving the larceny, theft, robbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or
(f)(11)(ii) (ii) A statement describing the applicable investigation, examination, litigation,…
IRCCourt RulingsMar 28, 2012related by meaning
ctive for determinations made after October 16, 2006, this Court has
jurisdiction to review an appeal from a determination by an Appeals officer under sec. 6330 without regard to the type of underlying tax involved. See Callahan v.
Commissioner, 130 T.C. 44, 48 & n.4 (2008).
- 6 -
Respondent does not dispute that petit…
IRCFinal Rules (FR)Dec 18, 2024related by meaning
tutional by a court of competent jurisdiction, all remaining provisions shall continue in effect.
IV. Procedural Requirements
A. Executive Order 12866 This rule is not a significant regulatory action as defined in E.O. 12866, dated September 30, 1993, as amended, and is not a major rule under 5 U.S.C. 804.
B. Administr…
IRCCourt RulingsOct 19, 2010related by meaning
re to pay his 2004 taxes; and
(4) whether the Court should impose a penalty under section
6673 for petitioner's advancement of frivolous or groundless arguments in proceedings instituted primarily for protest or
delay.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the par…
80 FR 57709 — Reliance Standards for Making Good Faith Determinations IRCFinal Rules (FR)Sep 25, 2015related by meaning
llection of information must be retained as long as their contents might become material in the administration of any internal revenue law.
Background This document contains amendments to 26 CFR part 53 under chapter 42, subtitle D of the Internal Revenue Code (Code). To avoid certain excise taxes under chapter 42, a p…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026related by meaning
Applicability Date
Proposed § 48.6435-1 would apply to removals of eligible dyed fuel occurring on or after December 31, 2025. See section 7805(b)(2). Special Analyses
I. Regulatory Planning and Review
These proposed regulations are not subject to review under section 6(b) of Executive Order 12866 pursuant to the Memor…
ERISACode / StatuteJan 6, 2025related by meaning
(f) (f) Biennial report Not later than the last day of the second calendar year after the calendar year including the applicability date of the final rules under section 342(e) of the SECURE 2.0 Act of 2022, and every 2 years thereafter, so long as the Secretary has received notices and post-offer reports under subsect…