IRCCourt RulingsApr 19, 1989related by meaning
e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026
…2
2026-6 2026-11 I.R.B. 2026-11 635
2026-7 2026-15 I.R.B. 2026-15 791
2026-8 2026-16 I.R.B. 2026-16 812
2026-9 2026-19 I.R.B. 2026-19 897
2026-10 2026-22 I.R.B. 2026-22 1515
Treasury Decisions:
Article Issue Link Page
10042 2026-03 I.R.B. 2026-03 320
10041 2026-04 I.R.B. 2026-04 360
10039 2026-05 I.R.B. 2026-05 403
100…
T.C. Memo. 2014-109 — Leslie J. Molinet Petitioner, and Michael F. Molinet, Intervenor v. Commissioner IRCCourt RulingsJun 9, 2014related by meaning
t available to the
spouse under section 6015(b) or (c). Sec. 6015(f)(1) and (2).
Subsections (b) and (c) of section 6015 apply only in the case of "an understatement of tax" or "any deficiency" in tax, and do not apply in the case of
underpayments of tax reported on joint tax returns. Sec. 6015(b)(1)(B), (c)(1);
Hopkin…
IRCPrivate Letter RulingsJun 17, 2016
…o § 1 035, no gain or loss is
recognized on the exchange. Similarly, Rev. Rul. 2002-75, 2002-2 C.B. 812, concludes
that an individual’s assignment of an annuity contract issued by one insurance company
to a second insurance company, which then deposits the cash surrender value of the
assigned contract into a pre-existi…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
IRCCourt RulingsAug 6, 1996
…al. Retail Clerks 85,567,809 84,810,863
S. Cal. UFCW 103,071,886 92,593,714
Central States SESW 909,812,563 725,079,000
UFCW M W Pension Plan 22,500,268 21,053,791
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
IRCCourt RulingsJul 14, 2005related by meaning
did not consider the
precedential effect of Beech Trucking Co. v. Commissioner, 118
T.C. 428 (2002) (Beech Trucking Co.), and (b) the factors used in determining whether a person is an employer or an employee24 that
the Court applied in Transport Labor I were inconsistent with the
common-law employment factors applied…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…,930 J. Employee contributions during year N/A 473,833 736,176 784,906
K. Interest to yearend
4
498,812 896,239 1,225,134 1,454,591
L. Account limit (yearend)
5
8,056,566 14,031,392 20,657,080 28,881,609
M. Actual contribution 30,689,717 2,170,000 13,966,816 12,247,933
N. Value of assets (yearend) 30,736,554 30,176,217…
IRCCourt RulingsJun 17, 1997
…453 --- --- ---
Other income: refund trustee fees --- --- --- --- 4,012
Tax exempt income 55,467 34,812 295,340 118,797 14,498
Total income 232,158 382,445 351,722 106,927 96,476
Taxes 10,306-0-13,572-0-7,519
Fiduciary fees 53,836 63,293 22,994-0 - - 0 -
Attorney, accountant 13,247 136,440 96,205 104,764 173,804
Other …
IRCPrivate Letter RulingsDec 1, 2006related by meaning
e emed
stock exceeded the value of annuities received in exchange).
Further, a relinquishment of inheritance rights is not regarded as a consideration in money or money’s worth. Section 25.2512-8. See also, Estate of Huntington v.
Commissioner
, 100 T. C. 313, 316 (1993), aff’d
, 6 F.3d 462 (1
st
Cir. 1994) (applying t…
IRCCourt RulingsFeb 22, 1999related by meaning
lating to petitioners' loan,
10.5 percent is the fair market interest rate.
V. Addition to Tax
Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to
file Form 5330 for each taxable year, or portion thereof, in the
taxable period. Sec. 6011; sec. 54.6011-1(…
IRCCourt RulingsApr 20, 2017related by meaning
See Parker v. Commissioner, T.C. Memo. 2012-66, 103
T.C.M. (CCH) 1321, 1323 (finding section 6201(d) inapplicable where the tax-
(continued...)
- 10 - [*10] Petitioner has not satisfied his burden of proof. He failed in his petition to
assign error to any of respondent's determinations, asserting instead that he had no…
IRCCourt RulingsMar 5, 2018related by meaning
¹² The Commissioner here also doesn't seek to redetermine income tax, but
only because the statute of limitations has run--he says if it hadn't, he'd redetermine the income tax too. We previously decided this was enough of a
distinction from Hellweg to let these cases go forward on the excise-tax issue
alone. Mazzei v…
IRCCourt RulingsFeb 28, 2024
…of State of Nev . v. S. Fork Band of Te- Moak Tribe of W. Shoshone Indians of Nev . , 339 F.3d 804, 812 (9th Cir. 2003). As in the case
of a waiver of sovereign immunity, here section 313 of the Act shortened
the period during which the Commissioner could assess tax in certain
circumstances. The provision “only applies…
IRCCourt RulingsJun 1, 1987related by meaning
6212(a), nor do we question whether respondent has issued valid statutory notices of deficiency. Compare Scar v. Commissioner, 814 F.2d 1363 (9th Cir. 1987), revg. 81 T.C. 855 (1983).
As we embark upon the Odyssey mandated by the interrelationships and cross-references of section 4975 and the applicable provisions of t…
IRCCourt RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…viewed in
the light most
.favorable to the nonmoving party . Dahlstrom v .
Commissioner , 85 T .C . 812, 821 ( :1985) . The moving party bears
the burden of demonstrating that no . genuine issue of material
fact exists and that the moving party is entitled to judgment as
a matter of law . Sundstrand Corp . v . Commissi…
IRCCourt RulingsApr 10, 2000
…e the underpayment for
purposes of imposing the penalty. See C.V.L. Corp. v.
Commissioner
, 17 T.C. 812, 816 (1951); McCauley v. Commissioner
,
T.C. Memo. 1988-431; sec. 1.6664-2(f), Income Tax Regs.; see also
Estate of Trompeter v. Commissioner
, 111 T.C. 57, 59-60 (1998),
and the cases cited therein.
10
We note that …
IRCCourt RulingsAug 12, 1980related by meaning
nstant case — to avoid the section 4973 excise tax.
We hold that Johnson is liable for the asserted excise taxes under section 4973 for 1975 and 1976. It appears that the notice of deficiency addressed to petitioners may be understood as asserting joint liabilities for the excise tax deficiencies. (See n.l supra) Since…