IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…
Notice 2024-2 — Miscellaneous Changes Under the SECURE 2.0 Act of 2022 IRCNoticesModified Jan 8, 2024
…ontributions credit taxable year (together, a 5-year employer contributions credit period). Section 102(c) of the SECURE 2.0 Act amends section 45E(e)(2) of the Code with respect to the disallowance of deductions for certain small employer plan startup costs and matching and nonelective contributions to take into accou…
IRCCourt RulingsMay 19, 1986related by meaning
…ulate that they are in contention. We do not, however, consider petitioner’s argument based on sec. 102, I.R.C. 1954, since it was not presented by the pleadings and was first raised on brief. See Professional Services v. Commissioner, 79 T.C. 888, 924 (1982); Markwardt v. Commissioner, 64 T.C. 989, 997 (1975).
These p…
IRCCourt RulingsJul 25, 2012
…etitioner argues that he received the IRA as an inheritance and therefore it is nontaxable. Section 102(a) provides that gross income does not include the
value of property acquired by, inter alia, inheritance. While an inheritance is
generally acquired tax free under section 102(a), distributions from inherited IRAs
t…
Notice 2018-84 — Notice 2018–84 provides interim guidance clarifying how the suspension of the personal exemption deduction in § 151(d)(5) of the Tax Cuts and Jobs Act applies … IRCNoticesNov 5, 2018related by meaning
the Code which refer to a taxpayer allowed a deduction (or an individual with respect to whom a taxpayer is allowed a deduction) under section 151.”). Section 36B allows a premium tax credit to eligible individuals who enroll themselves, their spouse, or any dependent (as defined in § 152) in a qualified health plan th…
IRCCourt RulingsAug 25, 1997
…further.
12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA),
Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is
generally applicable to proceedings commenced after Nov. 10,
1988. TAMRA sec. 6239(d), 102 Stat. 3746. Congress amended sec.
7430 most recently in the Taxpayer Bill of Rights 2 (TBOR2), Pub.
…
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…
78 FR 39870 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Jul 2, 2013
…31, and 1135; Secretary of Labor's Order 1-2003, 68 FR 5374; Sec. 2510.3-101 also issued under sec. 102 of Reorganization Plan No. 4 of 1978, 43 FR 47713, 3 CFR, 1978 Comp., p. 332 and E.O. 12108, 44 FR 1065, 3 CFR, 1978 Comp., p. 275, and 29 U.S.C. 1135 note. Sec. 2510.3-102 also issued under sec. 102 of Reorganizatio…
75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Jul 16, 2010
…ary of Labor's Order No. 1-2003, 68 FR 5374 (Feb. 3, 2003). Sec. 2550.401b-1 also issued under sec. 102, Reorganization Plan No. 4 of 1978, 43 FR 47713 (Oct. 17, 1978), 3 CFR, 1978 Comp. 332, effective Dec. 31, 1978, 44 FR 1065 (Jan. 3, 1978), 3 CFR, 1978 Comp. 332. Sec. 2550.401c-1 also issued under 29 U.S.C. 1101. Se…
IRCCourt RulingsDec 31, 1957related by meaning
y its shareholders, partners, or beneficiaries.
Sec. 430 (e) (1).
As stipulated.
Sec. 430 (e) (2) (B).
Sec. 430 (e) (2) (B) (1).
Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
84 FR 56894 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAProposed Rules (FR)Proposed Oct 23, 2019
…rticipants in the plan. The information required to be contained in the SPD is set forth in section 102(b) of ERISA. To the extent there is a material modification in the terms of the plan or a change in the required content of the SPD, section 104(b)(1) of ERISA requires the plan administrator to furnish participants …
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
84 FR 28888 — Health Reimbursement Arrangements and Other Account-Based Group Health Plans IRCFinal Rules (FR)Jun 20, 2019
on
131.
See, e.g.,
ERISA sections 102, 104(b), and 503 and PHS Act sections 2715 and 2719 (incorporated in Code section 9815 and ERISA section 715). See also26 CFR 54.9815-2715 and 54.9815-2719; 29 CFR 2520.102-3, 2520.104b-1, 2560.503-1, 2590.715-2715, and 2590.715-2719; and 45 CFR 147.136 and 147.200.
Back to Citat…
IRCCourt RulingsMar 15, 2004related by meaning
t 22, 2001,
respondent issued to petitioners a notice of deficiency
determining that they were liable for this additional tax in the
amount of $2,000. Discussion
I. General Rules
In general, section 408 governs the treatment of IRAs.
Specifically, section 408(d) provides that distributions from an
IRA are taxable in th…
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
IRCCourt RulingsJan 28, 2014related by meaning
vant facts." Lawinger v. Commissioner, 103 T.C. 428, 440 n.8 (1994).
- 24 -
[*24] Substantial authority exists only when the weight of the authorities supporting the treatment of the tax item is substantial in relation to the weight of
the authorities supporting contrary treatment. Sec. 1.6662-4(d)(3)(i), Income Tax
Re…
79 FR 51092 — Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Aug 27, 2014
…ecretary of Labor's Order 1-2011, 77 FR 1088 (Jan. 9, 2012); Sec. 2510.3-101 also issued under sec. 102 of Reorganization Plan No. 4 of 1978, 43 FR 47713, 3 CFR, 1978 Comp., p. 332 and E.O. 12108, 44 FR 1065, 3 CFR, 1978 Comp., p. 275, and 29 U.S.C. 1135 note. Sec. 2510.3-102 also issued under sec. 102 of Reorganizatio…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent.
Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
81 FR 35124 — Net Stable Funding Ratio: Liquidity Risk Measurement Standards and Disclosure Requirements IRCProposed Rules (FR)Proposed Jun 1, 2016
….
2. Netting of Certain Transactions The proposed rule would include a rule of construction in § __.102(b) that describes the treatment of receivables and payables that are associated with secured funding transactions, secured lending transactions, and asset exchanges with the same counterparty that the covered company…
IRCCourt RulingsAug 24, 1981related by meaning
s otherwise indicated. Unless otherwise indicated, any reference to "Rules” shall be deemed to refer to the Tax Court Rules of Practice and Procedure. The Court has concluded that the post-trial procedures of Rule 182 are not applicable in these particular circumstances. This conclusion is based on the authority of the…