73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner IRCCourt RulingsOct 30, 1979related by meaning
In addition, section 1.401(b)-1(e), Income Tax Regs., authorizes the Commissioner to further extend the remedial amendment period at his discretion. 7 *42 *188 This provision, upon which petitioner relies, confers discretionary authority on the Commissioner. When reviewing discretionary administrative acts, this Court …
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 …
IRCCourt RulingsMar 24, 1959related by meaning
s for such determination. Such statement shall not be used in the Tax Court of the United States as proof of the facts or conclusions stated' therein. “This subsection shall be applicable to all contracts and subcontracts, to the extent of the amounts received or accrued thereunder in any fiscal year ending after June …
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 RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
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…
IRCCourt RulingsAug 4, 1983related by meaning
earned income, qualifying for the maximum tax rate limitation. In the light of all the facts, we think respondent has the better side of the argument. Section 1348(a), in the form in which it was in effect in 1978, prescribed a 50-percent maximum tax rate limitation with respect to "personal service taxable income.” Se…
IRCCourt RulingsSep 14, 1993related by meaning
nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if—
(i) such lump sum distribution is received by an ind…
IRCCourt RulingsJul 21, 1993related by meaning
ntered for respondent.
Except as otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year at issue. Sec. 1122(a)(2) of the Tax Reform Act of 1986 (TRA 1986), Pub. L. 99-514, 100 Stat. 2085, 2466, replaced the theretofore applicable 10-year averaging with 5-year averagi…
85 FR 31714 — Income Tax Withholding on Certain Periodic Retirement and Annuity Payments Under Section 3405(a) IRCProposed Rules (FR)Proposed May 27, 2020related by meaning
in the Background section of the preamble, certain provisions of § 35.3405-1T reflect the rule under section 3405(a)(4) prior to amendment by TCJA.[3] Specifically, Q&As a-10, b-3, and b-4 of § 35.3405-1T each provide that the default rate of withholding on periodic payments is determined by treating the payee as marri…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
INCOME TAX
Notice 2006-60 Notice 2006-60
This notice announces that the Treasury Department and IRS will amend regulations section 1.45D-1 to provide guidance on how an entity meets the requirements to be a qualified active low-income community business when its activities involve certain targeted populations under sec…
T.D. 9779 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Section 83(b) permits the service prov… IRCTreasury DecisionsAug 15, 2016related by meaning
s in order to comply with their FATCA obligations, unless the FFIs qualify for an exemption under the FATCA regulations.
Notice 2016–48 Notice 2016–48 This Notice explains how the IRS will implement the changes to the Individual Taxpayer Identification Number (ITIN) program resulting from the enactment of the Protectin…
IRCCourt RulingsAug 13, 1999related by meaning
penses which are ordinary
and necessary and recurring in nature. Respondent relies on Rev.
Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring
expenses paid by an employer are not deductible under this
regulation. We disagree.
Our analysis starts at s…
36 T.C. 491 — Hiawatha Home Builders, Inc. v. Commissioner IRCCourt RulingsJun 9, 1961related by meaning
ter refer only to section 1551, the provisions of which are as follows :
SEC. 1551. ¡DISALLOWANCE OF SURTAX EXEMPTION AND ACCUMULATED EARNINGS CREDIT. If any corporation transfers, on or after January 1, 1951, all or part of its property (other than money) to another corporation which was created for the purpose of acq…