U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018related by meaning
C T
T.C. Memo. 201 8-92
UNITED STATES TAX COURT
VAL LANES RECREATION CENTER CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24887-10R. Filed June 26, 2018.
James R. Monroe and Michael A. Gilmer, for petitioner.
Nicholas D. Doukas and David Conrad, for respondent.
MEMORANDUM FINDINGS O…
75 FR 34538 — Interim Final Rules for Group Health Plans and Health Insurance Coverage Relating to Status as a Grandfathered Health Plan Under the Patient Protection and Aff… IRCFinal Rules (FR)Jun 17, 2010
… years (in the individual market, policy years) beginning on or after September 23, 2010.
See
§ 147.140 of this part for determining the application of this section to grandfathered health plans.
3. Section 147.140 is added to read as follows:
§ 147.140
Preservation of right to maintain existing coverage.
(a)
Definitio…
IRCNoticesFeb 18, 2025
…e the QPA pursuant to Treas. Reg. § 54.9816-6T(c)(4)(i), 29 CFR 2590.716-6(c)(4)(i), and 45 CFR 149.140(c)(4)(i). Under Treas. Reg. § 54.9816-6T(c)(4)(ii), 29 CFR 2590.716-6(c)(4)(ii), and 45 CFR 149.140(c)(4)(ii), for an item or service furnished in a subsequent year (before the first sufficient information year for t…
Notice 2023-4 — This notice provides the indexing factors to be used by group health plans and health insurance issuers to calculate the qualifying payment amount (QPA) for it… IRCNoticesJan 9, 2023
…fying payment amounts pursuant to § 54.9816-6T(c)(4)(i), 29 CFR 2590.716-6(c)(4)(i), and 45 CFR 149.140(c)(4)(i). Under § 54.9816-6T(c)(4)(ii), 29 CFR 2590.716-6(c)(4)(ii), and 45 CFR 149.140(c)(4)(ii), for such an item or service furnished in a subsequent year (before the first sufficient information year for the item…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
d was “not a consequence of a change at any time in the type, manner of operation, size, or condition of [its] business.” (Sec. 433 (b) (9) (C) (ii>.) At the outset we believe that the deduction for officers’ compensation constitutes a “class of deductions” within the meaning of section 433 (b) (9). McKay Machine Co., …
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
…zero by the amount of the AIR ($500,000 − $500,000). The reduced deduction limit is applied to O’s $140,000 of DDR attributable to services performed by O in L’s 2016 taxable year that is paid in 2018. Because $140,000 exceeds the reduced deduction limit of zero, the $140,000 is not deductible for L’s 2018 taxable year…
IRCCourt RulingsJul 5, 1983related by meaning
so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner IRCCourt RulingsOct 30, 1979related by meaning
ve amendment was contrary to the legislative intent. Aero Rental v. Commissioner, 64 T.C. 331, 342↩ (1975).
10. Sec. 301.7805-1 Rules and regulations. (b) Retroactivity↩. * * * The Commissioner may prescribe the extent, if any, to which any ruling relating to the internal revenue laws, issued by or pursuant to authoriz…
IRCProposed Rules (FR)Proposed Mar 12, 2026
…is chapter) or on the IRS website (
https://www.irs.gov)—
(1) Section 1.141-12(d)(4);
(2) Section 1.142(f)(4)-1; and
(3) Section 1.142-2(c)(2).
(b)
Applicability date.
This section applies to notices and elections filed on or after [the date 30 days after the date of publication of final regulations in the
Federal Regi…
IRCCourt RulingsAug 31, 1977related by meaning
defects arising from innocent inadvertence.”
See, however, sec. 401(b), which allows retroactive effect of amendments to the terms of employee plans. The stipulated facts are not clear on this point but indicate that the deduction for the contribution to the plans by Albets was not disallowed, presumably because respo…
IRCCourt RulingsJan 11, 2012
…evidence, that the determinations öf the
Commissioner in a notice of deficiency are incorrect. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Deductions
are a matter of legislative grace, and a taxpayer bears the
burden of proving entitlement to any claimed deductions. Rule
142(a) (1); INDOPCO, Inc. v. Comm…
IRCCourt RulingsJul 25, 1974related by meaning
ew principal place of work.
Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217.
SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
g at the time of
retirement”. G en. Signal Corp. v. Commissioner
, 142 F.3d at 549
(citing Parker-Hannifin Corp. v. Commissioner
, 139 F.3d 1090, 1094 (6th Cir. 1998)). We agree with respondent that the funding of the
reserve cannot begin until the reserve is created. However, we do
not agree with respondent that the r…
IRCCourt RulingsMay 20, 1976related by meaning
nd nondeferred compensation must be subject to the reasonable allowance standards set forth in section 162(a)(1). Sec. 1.404(a)-1(b), Income Tax Regs. Petitioners contend that if Congress intended section 404(a) to be subject to reasonable compensation standards, it would have specifically mentioned section 162(a)(1). …
IRCCourt RulingsJan 14, 2013related by meaning
sonable compensation and therefore not deductible under
section 162 (and thereby section 404), the 10% section 4972 excise tax applies to
that extent. V. Section 6651(a)(1) and (2) Additions to Tax
Respondent contends that the corporation is liable for section 6651(a)(1)
failure to file additions to tax of $10,050.95 a…
IRCCourt RulingsAug 29, 2006
…tions ar e
generally taxpayers
presumed correct, an d
burden of proving otherwise .' Rul e ear th e
142(a )( 1) ; Welch v . Ielvering , 290 U .S' . 111, 115 (1933 )
I . I . I
IRA Contribution Deduction I I
Tax deductions are a matter of legislative grace with the
taxpayer bearing the burden of proving entitlement to th…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsMay 29, 1997
…eterminations are presumed correct, and
petitioners have the burden of proving them erroneous. Rule 142(a); Welch v. Helvering
, 290 U.S. 111 (1933). Deductions are
a matter of legislative grace, and petitioners bear the burden of
proving their entitlement to any deduction claimed. Rule 142(a);
INDOPCO, Inc. v. Commiss…
IRCCourt RulingsAug 27, 2018
… Burden of Proof
Ordinarily, the burden of proof in cases before the Court is on the taxpayer.
Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). However, if the
Commissioner raises a new issue or seeks an increase in the deficiency, the
Commissioner bears the burden of proof as to the new issue or the increase…