IRCCourt RulingsDec 8, 1987related by meaning
ge of persons. See H. Rept. 93-1280 (Conf.) (1974), 1974-3 C.B. 415, 468.
Any reference to a Rule is to the Tax Court Rules of Practice and Procedure. It is undisputed that the application for exemption supplied the Commissioner with notice of the prohibited transactions. Such application was sent to both the Departmen…
IRCCourt RulingsOct 8, 2003related by meaning
ng this amount. Subsequently,
J.D. merged into Clarkston pursuant to section 368, and filed a
final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the
final return year of J.D. eliminated by book entry as a result of
the merger.
- 5 -
Discussion
Respondent’s …
IRCPrivate Letter RulingsAug 23, 2024
…xcept for the year(s) in which the contribution is distributed to the employee.
Retiree HRA Section 106 provides that gross income of an employee does not include employer -
provided coverage under an accident or health plan. Treas. Reg. § 1.106-1 provides
that the gross income of an employee does not include contribut…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
PLR 200302032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 10, 2003
…f the cash receipts and
disbursements method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106,
and Rev. Rul. 69-649, 1969-2 C.B. 106.
- 4 -
PLR-158362-01
Section 457(f) does not apply in this case to the amounts contributed to the
employee’s account in the supplemental health benefit or retirement plan. The
a…
PLR 200301032 — Annuities Purchased by Section 501(c)(3) Organizations or Public Schools IRCPrivate Letter RulingsJan 3, 2003
…f the cash receipts and
disbursements method of accounting. See also, Rev. Rul. 69-650, 1969-2 C.B. 106,
and Rev. Rul. 69-649, 1969-2 C.B. 106.
Section 457(f) applies in this case to the excess benefit amounts remaining in an
eligible employee’s sick and special leave accounts after the employer has contributed
the app…
IRCPrivate Letter RulingsAug 3, 2001
all compensation received for services performed including fringe
benefits.
Section 106 of the Code provides that the gross income of an employee does not include employer-provided coverage under an accident or health plan.
Section 1.106-1 of the Income Tax Regulations states that the gross income of
an employee does n…
IRCCourt RulingsOct 28, 1965related by meaning
ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
IRCCourt RulingsJul 11, 2024related by meaning
fits fall
under section 104 , or any other specific statutory exclusion , Mr. Tuma
instead seems only to have argue d for a general exclusion based on disability for which he provides no support in the Code and for which we
have found none .
11
We have previously held both railroad retirement
and Social Security benefi…
IRCCourt RulingsFeb 14, 1996
…intained such jurisdiction for a period of
- 40 -
4 months. Contrary to the language of section
601.106(d)(3)(iii)(a), Statement of Procedural Rules, however,
Appeals in this case did not arrange a settlement conference
within 45 days of receipt of petitioners' case. Petitioners
could not, therefore, have refused to pa…
89 FR 23338 — Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage IRCFinal Rules (FR)Apr 3, 2024
…se or illness, generally are considered “accident or health insurance” under sections 104, 105, and 106 of the Code, regardless of whether they are “excepted benefits” as defined in section 9832(c) of the Code. Premiums paid by an employer (including by salary reduction pursuant to section 125 of the Code) for accident…
IRCCourt RulingsMar 10, 2020related by meaning
sis test.
FIe] , further, as applied to P, I.R.C. sec. 72(t) is valid because
the age and disability classifications established by the statute bear a reasonable relationship to a legitimate Government purpose.
Sandra M. Conard, pro se.
Scott W. Forbord and Mark J. Miller, for respondent.
OPINION
TORO, Judge: A taxpaye…
IRCCourt RulingsOct 25, 1961related by meaning
recognized in section' ⅞,1 of. its regulations, set forth above.
See the last sentence of section 405(b) of the Defense Production Act of 1950, supra. We are not here called upon to decide whether taxpayers may appeal from the dis-allowance to us or any other court (see N. A. Woodworth Co. v. Kavanagh, supra; Oak Mfg. …
IRCCourt RulingsJul 11, 2012related by meaning
ditional tax provided by section 72(t)), penalties, and statutory
interest.. See Katz v. Commissioner, 115 T.C. 329, 338-339 (2000). The record
. 12 - does not establish that petitioners received a.notice of deficiency for 2007 and
consequently a challenge to petitioners' 2007 tax liability is allowed in thi
judicial p…
IRCCourt RulingsAug 28, 1996related by meaning
ented are contained
in pleadings and other documents in the record, and are not
controverted.
We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's
1991 taxable year. If respondent was not entitled to do so, then
the August notice would not be valid as…
IRCCourt RulingsAug 31, 2021related by meaning
g that there is a genuine dispute for trial.” Rule 121(d); see also Sundstrand
Corp. v. Commissioner , 98 T.C. at 520.
C. Standard and Scope of Review Where , as here, the validity of the underlying tax liability is not properly at
issue, the Court will review the Commissioner ’ s administrative determination for
abuse…