IRCCourt RulingsDec 19, 1974
…es which at first glance appear to support petitioner’s position herein. In Smith v. United States, 460 F.2d 1005, 1017-1018 (C.A. 6, 1972), a taxpayer was allowed capital gains treatment for a lump-sum distribution from a qualified profit-sharing plan in a situation where his separation from employment intervened betw…
IRCPrivate Letter RulingsJul 5, 2019
… the premise on which the deduction was initially based.
Hillsboro National Bank v. Commissione r , 460 U.S. 370 (1983); see also Hughes &
Luce, LLP v. Commissioner , 70 F.3d 16 (5
th
Cir. 1995), cert. denied , 517 U.S. 1208
(1996). The term “tax benefit rule” encompasses two concepts, an inclusionary part and
an exclu…
IRCCourt RulingsJul 21, 1993
…99-313, at 607-611 (1986), 1986-3 C.B. (Vol. 3) 1, 607-611; H. Conf. Rept. 99-841 (Vol. II), at 459-460, 462 (1986), 1986-3 C.B. (Vol. 4) 1, 459-460, 462. And the critical material in these reports is restated in substantially identical language in the Staff of Joint Comm, on Taxation, General Explanation of the Tax Re…
IRCCourt RulingsMar 5, 2018related by meaning
eded petitioners' contribution limits under section 408A and were
therefore excess contributions subject to section 4973 excise taxes for the years at issue, 2002-07. Consequently, the determinative question is whether the payments
- 21 -
from the FSC to the Roth IRAs were "contributions" under sections 408A and
4973.¹…
T.D. 9932 — Section 162(m)(1) of the Internal Revenue Code generally limits to $1,000,000 the allowable deduction for a taxable year for applicable employee remuneration p… IRCTreasury DecisionsJan 19, 2021
…0. This document contains final regulations to implement legislative changes to sections 263A, 448, 460, and 471 of the Internal Revenue Code (Code) that simplify the application of those tax accounting provisions for certain businesses having average annual gross receipts that do not exceed $25 million, adjusted for i…
IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…
T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated … IRCTreasury DecisionsDec 6, 2021
460 hours with an equivalent total cost of approximately $167,730,420. The cost and burden associated with the second year will be incurred in 2023.49 TABLE 7: Estimated One-Time Second-Year Cost and Hour Burden for Issuers and FEHB Carriers to Update and Maintain IT Systems and Submit Required Data
Number of Responden…
T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov… IRCTreasury DecisionsOct 6, 2014
…option exercise is $14,600 (($196 − $50) × 100). (ii) The $14,600 is attributed pro rata over the 1,460 days from January 1, 2016 to December 31, 2017 and from January 1, 2019 to December 31, 2020 (365 days per year for the 2016, 2017, 2019, and 2020 taxable years), so that $10 ($14,600 divided by 1,460) is attributed …
IRCCourt RulingsMay 20, 1976related by meaning
tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty.
OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…
REG-106796-12 — These proposed regulations provide guidance on the application of section 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for serv… IRCProposed Rules (FR)Proposed May 28, 2013
…on which E is not a service provider of V. Therefore, the $14,600 is attributed pro rata over the 1,460 days from January 1, 2016 to December 31, 2017 and from January 1, 2019 to December 31, 2020 (365 days per year for the 2016, 2017, 2019, and 2020 taxable years), so that $10 ($14,600 divided by 1,460) is attributed …
IRCCourt RulingsSep 17, 2026
…ment with the concept of a
“platform contribution transaction” (PCT). See T.D. 9441, 2009- 7 I.R.B. 460, 462– 63 .
4
[* 4 ] petitioner’s tax compliance services . The Form 211 reflects that
Target’s advisor generally explain ed to petitioner Target’s approach to
transfer pricing, which involved disaggregating transacti…
IRCCourt RulingsMar 15, 2011related by meaning
ner, T.C. Memo. 2005-70.
Section 401(a) sets forth the requirements that must be met
by a trust forming part of a profit-sharing plan in order for the trust to be eligible for favorable -tax treatment. Section
7476(a) confers jurisdiction on this Court to issue declaratory
judgments as to the initial and continuing qua…
IRCPrivate Letter RulingsApr 10, 2015
…nual accounting system
under specific circumstances. See Hillsboro Na tional Bank v. Commissioner , 460 U.S.
370, 377 (1983) . Generally, the tax benefit rule requires a taxpayer who received a tax
benefit from a deduction in an earlier year to recognize income in a later year if there
occurs an event that is fundament…
PLR 202503002 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJan 17, 2025
…e premise on
which the deduction was initially based. See Hillsboro National Bank v. Commissioner ,
460 U.S. 370, 383 (1983). The tax benefit rule will "cancel out" an earlier d eduction
when the later event is fundamentally inconsistent with the premise on which the
deduction was initially based, even if there is no a…
IRCCourt RulingsJan 19, 2010related by meaning
from qualified
retirement plans . :See, e .g ., Uscinski v . Commissioner , T .C .
Memo . 2 .005-124 (education expenses paid from a section .401(k)_ plan do not qualify for the exception . of ,section 72(t) (2) (E))- ;
Milner v . Commissioner , T .'C .` .Memo . 2004-111 (no "umbrell a
hardship exception" .for a distr…
PLR 202445015 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsNov 8, 2024
…e premise on
which the deduction was initially based. See Hillsboro National Bank v. Commissioner ,
460 U.S. 370, 383 (1983). The tax benefit rule will "cancel out" an earlier d eduction
when the later event is fundamentally inconsistent with the premise on which the
deduction was initially based, even if there is no a…
IRCCourt RulingsMay 14, 2012related by meaning
etitioner does not cite any relevant law to establish her position. We
similarly find none; and in the absence of congressional intent we note that we have strictly construed section 104(a)(1) to conform to the general purview of
section 61, that all income is taxable unless explicitly excluded. See Baldwin v.
Commissi…
IRCPrivate Letter RulingsNov 13, 2015
… the 60th
day after the day on which the individual received the payment or
distribution; or
3
201 ~460.18
(ii) the entire amount received (including money and any other property) is
paid into an eligible retirement plan
~other than an IRA) for the benefit of
such individual not later than the 60
1
day after the date o…
IRCCourt RulingsMar 5, 1987related by meaning
tions and are administered in a manner identical to the manner in which the payments to article III judges in regular active service are administered. Accordingly, petitioners are not here receiving the double tax benefit Congress sought to prevent by section 219(b)(2)(A).
Having decided that petitioners are entitled t…
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…