IRCCourt RulingsJan 14, 2013related by meaning
sonable compensation and therefore not deductible under
section 162 (and thereby section 404), the 10% section 4972 excise tax applies to
that extent. V. Section 6651(a)(1) and (2) Additions to Tax
Respondent contends that the corporation is liable for section 6651(a)(1)
failure to file additions to tax of $10,050.95 a…
IRCCourt RulingsFeb 22, 2010related by meaning
Print 1982) .
Sec . 7702 was enacted in 1984 as part of the Deficit Reduction
.
Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments
. postdate the promulgation of the
applicable regulations in 1956, for the reasons . discussed supra
we believe that the cross-reference to se…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
IRCCourt RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(6) civil penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
IRCCourt RulingsMay 28, 1962related by meaning
ion of the period allowed by the statute for such payment), by cash, check, note, property, or otherwise. Cf. Campbell Chain Co., 16 T.C. 1402 (1951). In the instant case it is clear that petitioner had no motive of tax avoidance in not making the payment within the prescribed time. Likewise no motive of tax avoidance …
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(8) civil penalty proceedings, this section shall apply in lieu of § 18.41 of this title.
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCPrivate Letter RulingsJun 11, 2004related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM
January 07, 2004
Number: 200424004
Release Date: 6/11/04
Third Party Contact:
Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04
CASE-MIS No.: TAM- 127815-03, CC:ITA:B07
Industry Director
------------------------------------------------
Taxpayer's Name…
IRCCourt RulingsMar 5, 2018related by meaning
sec. 924 to include gross
receipts from export sales or commission transactions.
24The amount computed under sec. 925(a)(1) could not exceed twice the amount computed under sec. 925(a)(2)--i.e., 46% of the combined taxable income
of the FSC and its related supplier from sale 1 and sale 2. Sec. 925(d).
25The FSC regulat…
IRCCourt RulingsJan 3, 2011related by meaning
nclude in gross income
the cash value of a life insurances policy held, by a multiemployer
Unless otherwise indicated, -section refer.ences are to the Internal oRevenue Code o f . 198 6 ( Code ) as amende d and in e f f ec t
for the year sin issue, andrRule- references are t o the Tax Court
Rules of Practicemand Proced…
ERISARegulationsJan 1, 2017related by meaning
For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCode / StatuteJan 6, 2025related by meaning
(r)(2)(B)(ii) (ii) After September 30, 1981, and before 1985 With respect to compensation paid before 1985 for services rendered after September 30, 1981, the tier 2 portion shall be—
(r)(2)(B)(ii)(I) (I) so much of the tax imposed by section 3201 as is determined at the 2 percent rate, and
(r)(2)(B)(ii)(II) (II) so mu…
76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner IRCCourt RulingsMar 17, 1981related by meaning
implement the congressional mandate in some reasonable manner.’ ” (Citations omitted.) Commissioner v. Portland Cement Co. of Utah, 450 U.S. _ (1981). H. Rept. 2333,77th Cong., 1st Sess. (1942), 1942-2 C.B. 372,413; S. Rept. 1631, 77th Cong., 2d Sess. (1942), 1942-2 C.B. 541, 606-607. The specific changes made by Congr…
IRCCourt RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
IRCCourt RulingsOct 19, 1981related by meaning
Private Letter Ruling 7939003. (Private letter rulings have no precedential authority. Sec. 6110(j)(3).) In this ruling, respondent stressed that sec. 269 was meant to apply in those circumstances where allowance of a given benefit would be inconsistent with the scheme Congress was attempting to encourage in enacting a…