IRCCourt RulingsMay 9, 1988related by meaning
e reasons stated herein, respondent former trustees’ motion to dismiss for lack of jurisdiction will be granted.
An appropriate order will be entered. These cases were assigned pursuant to sec. 7456 (redesignated as sec. 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1556, 100 Stat. 2755) and Rule 180. All s…
IRCCourt RulingsNov 25, 2008related by meaning
, after holding that the
taxpayer had no unpaid income tax for that year) ; Rowe v .
Commissioner , T .C . Memo . 2001-325 (holding that the Court has jurisdiction to review the Commissioner's denial of section
6015(f) relief from additions to tax and penalties) .
We hold that "taxes" in TRHCA section 408(c) includes t…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
75 FR 42605 — Increase in Tax Rates on Tobacco Products and Cigarette Papers and Tubes; Floor Stocks Tax on Certain Tobacco Products, Cigarette Papers, and Cigarette Tubes; … IRCFinal Rules (FR)Jul 22, 2010related by meaning
rom other large cigars. This commenter stated that “more refined information would make a valuable contribution to both tax and public health policy.” Since T.D. TTB-75 and Notice No. 93 did not address any changes to reporting categories, it would be inappropriate to consider any changes related to this issue in this …
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…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018
…k to Citation
96.
Id.
Back to Citation
97.
Table 1A, page 5 (stating that in coverage year 2015, 177.5 million persons of all ages were covered by employer sponsored insurance, with 135.7 million of those being covered by private sector employers), available at
https://www.dol.gov/sites/default/files/ebsa/resea…
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
- 8 -
[…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
IRCCourt RulingsApr 26, 1983
s from finding a gift where property worth $371,875 is exchanged for an annuity worth $177,500.92. See Estate of Bell v. Commissioner, 60 T.C. at 473. We also note that Marion did not seek to ascertain the cost of comparable commercial annuities before entering into the annuity agreement, a factor we have found to indi…
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 …
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
… of State lawsuits that stem from allegations of deceptive practices resulting in financial losses.[177]
For example, in 2018, the Ohio Office of Attorney General reported that Centene Corporation, which oversaw Ohio's Department of Medicaid prescription drug program, had engaged in spread pricing which cost the State …
IRCCourt RulingsAug 13, 1990related by meaning
3,155 710 442
12/31/84 4,025 .906 322
12/31/85 4,935 888 99
Respondent also determined a deficiency in second-tier tax under sec. 4975(b) of $101,843. Melvin C. Dace Docket No. 39553-87
Sec. 4975(a)
first-tier tax Additions to tax
TYE deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)
12/31/80 $1,936 $436 $484
12/31/81 4,926 1…
IRCProposed Rules (FR)Proposed Dec 23, 2025
…estimate that these proposed rules would affect 90,900 non-Federal governmental group health plans.[177]
Of these plans, approximately 35.7 percent [178]
(or 32,400) are self-insured,[179]
and 64.3 percent (or 58,400) are fully funded.[180]
2. Participants, Beneficiaries, and Enrollees
The Departments estimate that the…
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020
…3 Areas in which determination letters will not be issued
176
.04 Determination letter applications
177
.05 Review of determination letters
177
SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER?
178
.01 Scope of this section
178
.02 Scope of determination letters
178
.03 Design-based safe harbor
178
.04 Go…
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…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…ies agreed to an average price of $656,000 per finished lot and
estimated lot-finishing co st s of $177,000 per lot. On the b as is of these
terms, Mr. Duvall inferred a tract value of approximately $3.35 million
after accounting for the parties’ cost estimates. In another portion of
IRCCourt RulingsMar 20, 1997related by meaning
series of substantially
equal periodic payments made for life; (5) to an employee after
separation from service after attainment of age 55; or (6) as dividends paid with respect to corporate stock described in
section 404(k).
- 14 -
6
Sec. 4975 imposes two levels of excise tax on "any
disqualified person who participa…
IRCCourt RulingsAug 10, 2015related by meaning
mmissioner, 131 T.C. 185 (2008), supplementing T.C. Memo.
2007-340; Cyman v. Commissioner, T.C. Memo. 2009-144.
- 12 -
II. Section 1839
A. General Law Generally, the Internal Revenue Code allows deductions for ordinary and
necessary expenses incurred in conducting a trade or business or for the
production of income. Se…
IRCRegulationsJul 26, 2016
…the investment in the contract of $25,000, results in an adjusted investment in the contract of $23,177.50. If A dies before receiving payments for 15 years and the remaining payments are made to B, his beneficiary, B shall exclude the entire amount of such payments from his gross income until the amounts so received b…
IRCCourt RulingsJan 13, 1997related by meaning
7,676 represents the imposition of
additional tax under section 72(t) on petitioner's premature
retirement benefits distribution of $176,754.88. Since respondent asserts an increased deficiency, she has the burden of
proof on this issue. Rule 142(a). However, the parties
stipulated that $20,655.42 of that distribution …