IRCCourt RulingsAug 1, 1996related by meaning
1
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
T.C. Memo. 1996-354
UNITED STATES TAX COURT
BRENT ALLAN PULLIAM, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket…
IRCCourt RulingsMay 5, 2008
… section 6015(f), the Commissioner has
prescribed guidelines in Rev . Proc . 2003-61, 2003-2 C .B . 296,
modifying Rev . Proc . 2000-15, 2000-1 C .B . 447, that are to be
used in determining whether it is inequitable to hold a
requesting spouse liable for all or part of the deficiency .'
Rev . Proc . 2003-61, sec . 4 .…
89 FR 84314 — Privacy Act Regulation; Exemption for Legal Case Management Records PBGCProposed Rules (FR)Proposed Oct 22, 2024related by meaning
Document Headings
Document headings vary by document type but may contain
the following:
the agency or agencies that issued and signed a document
the number of the CFR title and the number of each part
the document amends, proposes to amend, or is directly
related to
the agency docket number / agency internal file numb…
75 FR 41726 — Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable… IRCFinal Rules (FR)Jul 19, 2010
…ursuant to the authority contained in sections 2701 through 2763, 2791, and 2792 of the PHS Act (42 USC 300gg through 300gg-63, 300gg-91, and 300gg-92), as amended.
76 FR 49570 — Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests IRCFinal Rules (FR)Aug 10, 2011
…nnuity of $32,712.72 per year payable for 18 years or until the prior death of a person aged 60 is $296,887.56 ($32,712.72 × 9.0756). Thus, the present value of the charitable annuity interest is $893,900.68 ($597,013.12 + $296,887.56).
* * * * *
(4)
Example.
The provisions of paragraph (b)(3) of this section are illus…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
s follows:
Authority:
26 U.S.C. 7805 * * *
Section 301.6011-10 also issued under 26 U.S.C. 6011.
Section 301.6011-11 also issued under 26 U.S.C. 6011. Section 301.6011-12 also issued under 26 U.S.C. 6011.
Section 301.6011-13 also issued under 26 U.S.C. 6011.
Section 301.6011-14 also issued under 26 U.S.C. 6011.
Section…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-263
UNITED STATES TAX COURT
RICHARD J. MONTGOMERY AND ADELE S. MONTGOMERY, Petitioners v
.
COMMISSI…
IRCCourt RulingsFeb 9, 2023related by meaning
lieved that
the executive branch should conduct a comprehensive study of the 1968
regulations, and that the executive branch should carefully consider whether the 1968 regulations should be modified “in any respect.” H.R.
Conf. Rept. No. 99-841 (Vol. II), at II - 638 , 1986- 3 C.B. (Vol. 4) at 638.
Petitioner has a con…
PBGCRegulationsJan 1, 2017
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable rules under those requirements for determining the filing and issuance date. (Subpart A tells you what filing methods you may use for filings with us…
PBGCRegulationsJan 1, 2017
…t use a “designated delivery service” under section 7502(f) of the Internal Revenue Code (Title 26, USC). Our Web site, http://www.pbgc.gov, lists those designated delivery services. You should make sure that both the provider and the particular type of delivery (such as two-day delivery) are designated.
IRCCourt RulingsApr 2, 2020related by meaning
e conditions named in section 6404(e)(1) are met. The word "may"
- 18 -
[*18] signifies that Congress has conferred discretion on the Secretary of the Treasury. C[ Porter v. Commissioner, 132 T.C. 203, 206-208 (2009), abrogating
Butler v. Commissioner, 114 T.C. 276 (2000); see also id. at 237-238 (Gustafson,
J., dissen…
PBGCRegulationsJan 22, 2018
…r than in the PBGC's own regulations (e.g., requirements under the Internal Revenue Code (Title 26, USC)). In meeting those requirements, you should follow any applicable computation-of-time rules under those other requirements. (Subpart A tells you what filing methods you may use for filings with us. Subpart B tells y…
84 FR 51494 — Benefit Payments and Allocation of Assets PBGCProposed Rules (FR)Proposed Sep 30, 2019related by meaning
Document Headings
Document headings vary by document type but may contain
the following:
the agency or agencies that issued and signed a document
the number of the CFR title and the number of each part
the document amends, proposes to amend, or is directly
related to
the agency docket number / agency internal file numb…
IRCCourt RulingsJun 3, 1998related by meaning
T.C. Memo. 1998-203
UNITED STATES TAX COURT
RAMON A. GARCIA AND BERTHA E. GARCIA, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21532-95. Filed June 3, 1998.
Richard M. Taylor
and James E. McCutcheon III
, for
petitioners.
Elizabeth A. Owen
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPI…
IRCCourt RulingsOct 25, 1961related by meaning
ust be made upon each individual partner against whose interest in such partnership it is intended to request the imposition of a sanction.
⅜' ***** * Section 6.1 Certificate of disallowance. — Whenever there has been a final decision in an enforcement proceeding imposing a disallowance sanction, as defined in section …
Rev. Proc. 2006-27 — Administrative programs; correction programs. This procedure updates and expands upon the Service’s comprehensive Employee Plans Compliance Resolution System (… IRCRevenue ProceduresSuperseded May 30, 2006related by meaning
essed pursuant to a VCP submission, the Service reserves the right to make a referral of the abusive tax avoidance transaction matter for examination. (c) Audit CAP and SCP (for plans Under Examination). For plans Under Examination, if the Service determines that the plan or Plan Sponsor was, or may have been, a party …
IRCCourt RulingsJun 14, 2012related by meaning
ause, petitioners must show that the assessment of the penalties is so
harsh and oppressive as to transgress the constitutional limitation: See, e.g., McGehee Family Clinic v. Commissioner, T.C.:Memo. 2010-202. The penalty
structure of section 6662A does not do so
Petitioners also contend that their due process rights …
88 FR 76660 — Technical Amendments: Special Financial Assistance Withdrawal Liability Condition; SECURE 2.0 Act; and Other Updates PBGCFinal Rules (FR)Nov 7, 2023related by meaning
a speech disability, please dial 7-1-1 to access telecommunications relay services”.
§ 4000.28
[Removed and Reserved]
3. Remove and reserve § 4000.28. PART 4003—RULES FOR ADMINISTRATIVE REVIEW OF AGENCY DECISIONS
4. The authority citation for part 4003 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3).
§ 40…
IRCCourt RulingsApr 30, 1997related by meaning
lendar year, with the names of David Chiu, or David
Chiu and Shere Yau, listed and a description of various
items (marked as petitioner's Exhibit 10). Respondent objects to the admission of the foregoing on the
grounds of relevance, authentication, hearsay, and completeness.
We conclude that respondent is not prejudice…
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
y action proceeding. Since petitioners have not provided notice to employees and other interested parties, we hold that their pleadings are premature. Since we are presently discussing the statutory scheme, as opposed to the regulations or the legislative history, it is appropriate that we now outline two of petitioner…