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Go to T.C. Memo. 1979-23 (not yet in the library — opens the official source)
54 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
  2. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
  3. 88 T.C. 1440; 88 T.C. No. 80 — Lambos v. Commissioner
    IRCCourt RulingsJun 1, 1987
    …posed under section 4975(a) as follows: Petitioner TYE Deficiency Olga Lambos (Olga) 1976 1977 1978 1979 1980 1981 $228.00 684.00 1,140.00 1,596.00 2,052.00 2,508.00 Anton Lambos (Anton) and Olga Lambos 1976 1977 1978 1979 1980 1981 487.50 975.00 1.462.50 1,950.00 2.437.50 2,925.00 The issues for decision are (1) wheth…
  4. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    , or documents to which §6104 (document open to public inspection) applies, as described in section 10.03. Taxpayer may protest deletions not made .05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
  5. PLR 200118016 — Notification of Secretary of Labor
    IRCPrivate Letter RulingsMay 4, 2001related by meaning
    …30-00/CC:TEGE:EB:QP1 UILC: 4975.07-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area Attn: Laura Beth Heisen FROM: Michael Roach, Chief CC:TEGE:EB:QP1 SUBJECT: Adequacy of Department of Labor Notification Pursuant to I.R.C. §4975(h)…
  6. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
  7. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM January 07, 2004 Number: 200424004 Release Date: 6/11/04 Third Party Contact: Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04 CASE-MIS No.: TAM- 127815-03, CC:ITA:B07 Industry Director ------------------------------------------------ Taxpayer's Name…
  8. 85 FR 72846 — Financial Factors in Selecting Plan Investments
    ERISAFinal Rules (FR)Nov 13, 2020
    …uart Cohen, General Motors Corp. (May 14, 1993). Back to Citation 27.  44 FR 37221, 37225 (June 26, 1979). Back to Citation 28.  44 FR at 37222 (June 26, 1979) (emphasis added). Back to Citation 29.  See 29 CFR 2509.94-1 and 2509.2015-01. Back to Citation 30.  See Hecker v. Deere & Co., 556 F.3d 575, 586 (7th Cir. 2009…
  9. 71 T.C. 332 — Brownholtz v. Commissioner
    IRCCourt RulingsDec 4, 1978related by meaning
    ould be noted that these two paragraphs of the regulations (sec. 1.72-15(b) and (d), Income Tax Regs.) were adopted in 1960 (see T.D. 6485,1960-2 C.B. 28), long before promulgation of the challenged paragraph (sec. 1.72 — 15(i), Income Tax Regs.) in 1975 (T.D. 7352,1975-1 C.B. 34). Petitioner’s attack on the validity o…
  10. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986
    …d in the decedent’s gross estate. This approach is clearly applicable to the gifts made in 1978 and 1979, the years for which petitioner seeks $3,000 exclusions. The Revenue Act of 1978, Pub. L. 95-600, 92 Stat. 2930, specifically made its revision effective for transfers of gifts on January 1, 1977, and later. Only fo…
  11. IRCCourt RulingsOct 12, 1978related by meaning
    other than that presented before the Internal Revenue Service and contained in the administrative record as so defined. * * * See also Rule 210(c)(4). Here, the petitioner timely filed his comment letter with the District Director in which he raised four specific "matters." As to such matters, he exhausted his administ…
  12. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980
    OPINION Hall, Judge: Petitioner Jorj Judd (Jorj) is a cosmetologist. On March 29, 1979, respondent mailed a statutory notice asserting a deficiency in petitioners’ 1976 joint tax return of $1,317. Part of the deficiency related to $2,300 in unreported tips allegedly received by Jorj during the course of her 1976 employ…
  13. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005related by meaning
    gard to any burden-shifting rule. See Williams v. Commissioner , 123 T.C. 144 (2004). Background This case was submitted to the Court fully stipulated pursuant to Rule 122. Petitioner resided in Berwyn Heights, Maryland, when she filed her petition in this case. A. Service Provided to the State Department Pursuant to P…
  14. 78 T.C. 812; 78 T.C. No. 57 — Service Bolt & Nut Co. Profit Sharing Trust v. Commissioner
    IRCCourt RulingsMay 20, 1982
    …error. A statutory notice is now being prepared and will be issued at an early date.” On January 8, 1979, the Cincinnati Service Center abated the prior assessments of tax and penalties and so notified each petitioner. On November 1, 1979, statutory notices of deficiency were issued to each of petitioners. On December …