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…
PLR 200524016 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsJun 17, 2005
…ed in the administration of tax laws. However,
Section 3 of the "Defense of Marriage Act", P.L. 104-199 (September 21, 1996),
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20… IRCRevenue ProceduresJan 2, 2019
…CTION 24. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS ISSUE LETTER RULINGS?
199
.01 Scope limited to issues specified
199
.02 Generally not in employee plans qualification matters
200
.03 Request to Employee Plans Rulings and Agreements for extension of time for making an election or for other r…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
IRCCourt RulingsApr 11, 2012
ability Equity Trust for Dr. White as follows:
Year Deduction
1999 $50,000
2000 50,000
2001 50,000
2002 50,000
2003 -02004 4,00d
(continued...)
- 11 - The xélan 419 Plan
The xélan 419 plan was established in 1997 with a trust agreement dated
December 5, 1997, and was designed to be a "10 or more employer plan" within
t…
77 FR 8725 — Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable Care Act IRCFinal Rules (FR)Feb 15, 2012related by meaning
health plans
Health care
Health insurance
Medical child support
Reporting and recordkeeping requirements
45 CFR Part 147
Health care
Health insurance Reporting and recordkeeping requirements, and State regulation of health insurance
DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Chapter I
Accordingly, 26 C…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
…ade by the Taxpayer Bill of Rights II, the Internal Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004.
GIFT TAX
T.D. 9473 T.D. 9473
Final regulations under section 6159 of the Code relate to the payment of tax liabilities in installments and reflects changes to the law mad…
IRCCourt RulingsOct 29, 2013related by meaning
…n one of the
identified transactions under section 4975. Janpol v. Commissioner, 101 T.C. 518,
525 (1993).
The purpose of section 4975, in part, is to prevent taxpayers involved in a
qualified retirement plan from using the plan to engage in transactions for their
own account that could place plan assets and income at …
IRCCourt RulingsJul 24, 1991related by meaning
tever source derived, including (but not limited to) the following items: *******
(11) Pensions;
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
IRCCourt RulingsMay 29, 2002related by meaning
…er, there was no levy by respondent in this case.
Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13,
affd. without published opinion 166 F.3d 1201 (2d Cir. 1998),
also cited by petitioner, the taxpayer was indicted on charges of
violating Federal currency transaction reporting laws. As part
of the taxpayer's pl…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
IRCCourt RulingsFeb 5, 1998
…y all of
- 13 -
petitioners' claimed bad debt deductions. See Williams v.
Commissioner , T.C. Memo. 1994-560.
It is not clear whether petitioners are also making an
argument that money advanced to the partnerships by ISI should be
viewed as increasing Mr. Bach's basis in the partnerships for
purposes of determining the…
IRCCourt RulingsNov 17, 2016related by meaning
culating the required reduction in the section 415 dollar limitation.
Accordingly, inasmuch as respondent applied this method to calculate the reduced benefit limitation under section 415(b)(2)(C) for the plan, his calculations of the
age 45 limits for tax years 2002 through 2006 are correct.
III. Petitioner's Liabilit…
IRCPrivate Letter RulingsJul 8, 2016
…of a trust agreement for tax law purposes
in Estate of La Meres v. Commissioner , 98 T.C. 294 (T.C. 199 2). In La Meres , a state
probate court order approved the post-death amendment of a trust to eliminate a
provision that caused adverse estate tax results, and held that such amendment was
IRCPrivate Letter RulingsJul 8, 2016
…of a trust agreement for tax law purposes
in Estate of La Meres v. Commissioner , 98 T.C. 294 (T.C. 199 2). In La Meres , a state
probate court order approved the post-death amendment of a trust to eliminate a
provision that caused adverse estate tax results, and held that such amendment was
Rev. Rul. 2024-1 — This revenue ruling provides tables of covered compensation under § 401(l)(5)(E) of the Internal Revenue Code and the Income Tax Regulations thereunder, effect… IRCRevenue RulingsJan 8, 2024related by meaning
the statutorily-required exceptions will be provided to these phaseouts if construction begins on or after January 1, 2025.
Notice 2024-11, page 360. This notice updates Notice 2011-64, 2011-37 I.R.B. 231, which contains the list of treaties that meet the requirements of section 1(h)(11)(C)(i)(II) of the Code. It adds…
PLR 200301032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 3, 2003
…y to the portion of
the contributions allocable to the accident or health benefits.
In Rev. Rul. 62-199, 1962-2 CB 38, the Service concluded that section 106
applies to retired employees as well as active employees.
Section 403(b)(1) of the Code states, in part, that amounts contributed by an
eligible employer to a tax…
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
…Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissioner
, 101 T.C. 189, 194
(1993); cf. S. Rept. 1567, 75th Cong. 3d Sess. at 24 (1938),
1939-1 C.B. (Part 2) 779, 796.
- 12 -
5
The amendment was adopted in 1988. See Technical and
Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat.
3704.…