64 T.C. 1011 — Catawba Industrial Rubber Co. v. Commissioner IRCCourt RulingsSep 9, 1975
…meet the requirements of sec. 401(a)(3), (4), (5), and (6) in sec. 401(b). See Aero Rental, 64 T.C. 331 (1975). Respondent agrees that this fact alone would not negative the existence of a qualified trust in petitioner’s fiscal year 1972, if a contribution was made to an existing trust within the grace period provided …
IRCCourt RulingsJul 6, 2022related by meaning
and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. ,
98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light
most favorable to the nonmoving party (here respondent) . Sundstrand
4
On December 13, 2021, petit…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006
…02(e)(2) business terminations are not subject to this provision.)
(23) Sections 302(b)(4) and (e), 331, 332, and 346(a).—Effects on Recipients of Distributions in Corporate Liquidations.—The tax effect of the liquidation of a corporation preceded or followed by the transfer of all or a part of the business assets to a…
IRCCourt RulingsJul 24, 1995
…bserved. Taylor v. Commissioner, 67 T.C. 1071, 1077 (1977); Sperapani v. Commissioner, 42 T.C. 308, 331 (1964). On the other hand, if the requirements are procedural or directory in that they do not go to the essence of the thing to be done, but rather are given with a view to the orderly conduct of business, they may …
IRCCourt RulingsNov 26, 1969
…es in its service. United States v. Martin, 337 F. 2d 171 (C.A. 8, 1964); United States v. Peebles, 331 F. 2d 955 (C.A. 5, 1964); United States v. Johnson, 331 F. 2d 943 (C.A. 5, 1964) ; Jack E. Schlegel, 46 T.C. 706, 708 (1966); see also E. N. Funkhouser, 44 T.C. 178 (1965), aff'd. 375 F. 2d 1 (C.A. 4, 1967); Victor S…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…02(e)(2) business terminations are not subject to this provision.)
(23) Sections 302(b)(4) and (e), 331, 332, and 346(a).—Effects on Recipients of Distributions in Corporate Liquidations.—The tax effect of the liquidation of a corporation preceded or followed by the transfer of all or a part of the business assets to a…
IRCCourt RulingsJan 9, 1985related by meaning
t that previously was not subject to the penalty. Samuels v. McCurdy, 267 U.S. 188 (1925); Chicago & Alton Railroad v. Tranbarger, 238 U.S. 67 (1915). We note that petitioner can avoid payment of the section 4975(b) tax by correcting the prohibited loans before our decision herein becomes final. Secs. 4961 and 4962.
To…
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
… that the suggested changes are inconsistent with the general principle in the Act and in 31 CFR 29.331. Section 29.331 provides that all requirements must be satisfied as of June 30, 1997, for service to be creditable towards a Federal Benefit Payment. In turn, the general principle is consistent with section 11012(b)…
IRCCourt RulingsSep 15, 2005related by meaning
tinued...)
- 5 -
of the Secretary, and in the same manner as taxes. Sec.
6652(c) (4) (A).
Section 6331(a) provides that, if a person liable to pay any tax neglects or refuses to do so within 10 days after notice and
demand, the Secretary can collect the tax by levy upon the
property belonging to the person, subject to …
IRCCourt RulingsAug 27, 2018related by meaning
0 and $5,379, respectively; and
(4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014
of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a)
penalties in writing by making an entry in the Correspondence Examination
Automation Case Support…
85 FR 31710 — Guidance Clarifying Premium Tax Credit Unaffected by Suspension of Personal Exemption Deduction IRCProposed Rules (FR)Proposed May 27, 2020related by meaning
e made electronically. If a public hearing is scheduled, notice of the date, time, and place for the hearing will be published in the
Federal Register . Announcement 2020-4, 2020-17 IRB 1, provides that until further notice, public hearings conducted by the IRS will be held telephonically. Any telephonic hearing will b…
PBGCCode / StatuteJan 6, 2017related by meaning
(c) (c) Priority
(c)(1) (1) Except as otherwise provided under this section, the priority of a lien imposed under subsection (a) shall be determined in the same manner as under section 6323 of title 26 (as in effect on April 7, 1986). Such section 6323 shall be applied for purposes of this section by disregarding subse…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
ns
were made negligently or intentionally.”) (emphasis added);
see Mathews
v.
Chevron Corp.,
362 F.3d 1172, 1183 (9th Cir. 2004).
Back to Citation
37. 84 FR 33348, note 303. The Department observes that this requirement is also consistent with, for example, the requirement under section 206 of the Advisers Act, which …
IRCProposed Rules (FR)Proposed Nov 27, 2019
… Departments estimate the total one-time hour burden for all health insurance issuers and TPAs of 2,331,210 hours and an associated equivalent cost of approximately $211,386,679 to develop and build the Negotiated Rate File in a machine-readable format. In subsequent years, the Departments estimate the total annual hou…
87 FR 62316 — Actuarial Assumptions for Determining an Employer's Withdrawal Liability PBGCProposed Rules (FR)Proposed Oct 14, 2022
…appeals filed,
Nos. 21-55864, 21-55923;
Manhattan Ford Lincoln, Inc.
v.
UAW Local 259 Pension Fund,
331 F. Supp. 3d 365 (D.N.J. 2018) (re blended rates),
appeal voluntarily dismissed; New York Times Co.
v.
Newspaper and Mail Deliverers'-Publishers' Pension Fund,
303 F. Supp. 3d 236 (S.D.N.Y. 2018) (re blended rates),
a…
76 FR 66136 — Investment Advice-Participants and Beneficiaries ERISAFinal Rules (FR)Oct 25, 2011
…terba
et al., Asset Location for Retirement Savers, inPublic Policies and Private Pensions
290, 290-331 (John B. Shoven
et al.
eds., 2004); John B. Shoven & Clemens Sialm,
Asset Location in Tax-Deferred and Conventional Savings Accounts,
Journal of Public Economics, Volume 88 (2003); James M. Poterba
et al., Asset Loca…
IRCCourt RulingsMay 19, 2011related by meaning
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
IRCCourt RulingsNov 24, 1971
er Ward T. Richards on or about August 3, 1967, and the amount of $4,331.67 was distributed to petitioner Homer N. Ackerman on or about August 3,1967. In connection with the distributions on or about August 3, 1967, petitioners Homer N. Ackerman and Ward T. Richards each received a letter dated August 3, 1967, from the…
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…