IRCCourt RulingsJul 23, 2003
…gage Interest Expense
Petitioners claimed an itemized deduction for mortgage
interest expense of $8,732 in 1996. Respondent decreased this
deduction, allowing a deduction of only $3,732.
Mortgage interest expense generally is deductible by
individual taxpayers, subject to various limitations not relevant
here. Sec. 163…
50 T.C. 391 — New York Seven-Up Bottling Co. v. Commissioner IRCCourt RulingsMay 29, 1968related by meaning
-10(a). Upon considering the entire regulation in the perspective of the issue raised herein, we conclude that petitioner’s argument is without merit. We conclude that section 404 (a) applies to petitioner’s severance-pay provision. It follows that section 404(a) (5) prohibits petitioner from deducting the sum of $36,7…
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…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015
…
the premium on additional paid-up insurance on the Blake policy. The Sterling
Plan later used $390,732 of the $450,000 to pay the premiums on the life
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insurance policies covering all of Our Country's employees, including Mr. Blake.
Of the $390,732, $323,606 was paid on the Blake policy.
Under the Sterling plan,…
IRCCourt RulingsFeb 25, 1959related by meaning
ration from the service” within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners. In Mary Miller, 22 T.C. 293, affd. 226 F. 2d 618, the May Company acquired all the assets of the Strouss-Hirshberg Company in exchange for May Company stock. Three days …
IRCCourt RulingsMar 11, 2020related by meaning
little more than guesswork and failed to satisfy the strict substantiation
requirements for vehicle expenses prescribed in section 274(d) and related regulations. As noted above the Court may not use the rule established in Cohan
v. Commissioner, 39 F.2d at 543-544, to estimate expenses covered by section
274(d). Cons…
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…
79 FR 10296 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act IRCFinal Rules (FR)Feb 24, 2014
… enrollment periods in addition to those required under section 701(f) of the Act.
* * * * *
§ 2590.732
[Amended]
22. Section 2590.732 is amended by removing paragraph (b)(2)(i), and redesignating paragraphs (b)(2)(ii) through (b)(2)(ix) as (b)(2)(i) through (b)(2)(viii).
IRCCourt RulingsDec 14, 1976related by meaning
. 401(d)(3)(A) and (B).
Sec. 401(d)(2)(A).
Sec. 401(d)(2)(B).
Sec. 401(d)(5); sec. 404(e)(1), (e)(2)(A), and (e)(4).
Sec. 72(m)(5).
Sec. 401(a)(9)(A). Sec. 406, Employee Retirement Income Security Act of 1974; sec. 4975; see also former sec. 503(j), which accompanied the adoption of sec. 401(c)(3)(B).
H. Rept. No. 378,…
IRCCourt RulingsApr 19, 2004related by meaning
the payment of such tax. * * *
Section 6334(a) exempts from levy: (1) Wearing apparel and
school books; (2) fuel, provisions, furniture, and personal effects; (3) books and tools of a trade, business, or profession;
(4) unemployment benefits; (5) undelivered mail; (6) certain
annuity and pension payments; (7) workmen’…
AO 2020-01A — Whether LP Management's limited partnership programs are employee welfare benefit plans within the meaning of section 3(1) of ERISA, and, if so, whether the ar… ERISADOL Advisory Opinions
…ck their personal activities on their electronic devices. You additionally argue that ERISA section 732(d) supports LP Management’s position, but this argument too is unpersuasive. Section 732(d) provides “for purposes of this part,” [i.e., Part 7 of ERISA] that “[a]ny plan, fund, or program which would not be (but for…
89 FR 104040 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age; Missing Participants Mortality Assumption PBGCFinal Rules (FR)Dec 20, 2024
…From—
To—
2026
825
825
3,486
3,486
2027
844
844
3,566
3,566
2028
864
864
3,648
3,648
2029
884
884
3,732
3,732
2030
904
904
3,818
3,818
2031
925
925
3,906
3,906
2032
946
946
3,996
3,996
2033
968
968
4,088
4,088
2034
990
990
4,182
4,182
2035 or later
1,013
1,013
4,278
4,278
1
Applicable tables for valuation dates before…
88 FR 87968 — Definition of “Employer”-Association Health Plans ERISAProposed Rules (FR)Proposed Dec 20, 2023
… to paragraph (2)) as an employee welfare benefit plan which is a group health plan.” ERISA section 732(d); PHS Act section 2722(d). For a group health plan, the term employee also includes any bona fide partner. 26 CFR 54.9831-1(d)(2); 29 CFR 2590.732(d)(2); 45 CFR 146.145(c)(2).
Back to Citation
74.
See, e.g., Grub…
IRCCourt RulingsOct 11, 1995related by meaning
tion that petitioners
are liable for the 10-percent additional tax imposed by section
72(t).
Section 72(t) provides for a 10-percent additional tax on early distributions from qualified retirement plans. Paragraph
(1), which imposes the tax, provides in relevant part as follows:
(1) Imposition of Additional Tax.--If an…
IRCCourt RulingsAug 1, 2012related by meaning
yer's return information. None of the assertions, even if true,
would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack
merit and will not be addressed in this opinion. Adverse rulings are not grounds
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[…
IRCCourt RulingsAug 12, 1980related by meaning
.
Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
each employee, petitioner is entitled to a deduction under section 404(a)(5) for fiscal 1967 and fiscal 1968.
Decision will be entered under Rule 155. The record does not reveal when a copy of the proposed definitive deed was submitted to Inland Revenue.
The interim deed, by itself, was merely a seven-page document est…
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’ …
89 FR 34106 — Definition of “Employer”-Association Health Plans ERISAFinal Rules (FR)Apr 30, 2024
…ubject to paragraph (2)) as an employee welfare benefit plan which is a group health plan.” Section 732(d) of ERISA; Section 2722(d) of PHS Act. For a group health plan, the term employee also includes any bona fide partner. 26 CFR 54.9831-1(d)(2); 29 CFR 2590.732(d)(2); 45 CFR 146.145(c)(2).
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87.
See…
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…