IRCCourt RulingsFeb 15, 2002
spouse, or a dependent (as
defined in section 152)”. While petitioner’s mother could have
been his dependent, see sec. 152(a)(4), in order for her to qualify as his dependent, petitioner would have had to provide
over half of her support, sec. 152(a). We note that not only is
the record totally devoid of any evidence …
IRCCourt RulingsSep 21, 2017
ependent (as defined in section 152) of the taxpayer for the taxable
year." Sec. 151(c). Section 152(a) defines a "dependent" to include a "qualifying child". Generally, a "qualifying child" must: (1) bear a specified relationship to
the taxpayer; (2) have the same principal place of abode as the taxpayer for more
than…
IRCCourt RulingsJul 30, 1985related by meaning
…inning after Dec. 31, 1981. See sec. 311(a), Economic Recovery Act of 1981, Pub. L. 97-34, 95 Stat. 172, 274. This change was not made retroactive.
We have found no cases decided on this issue by the Court of Appeals for the Ninth Circuit; this case would be appealable to the Ninth Circuit. Golsen v. Commissioner, 54 T…
IRCCourt RulingsMar 25, 2013
…poration has a limited number of officers. Charles Schneider &
Co. v. Commissioner, 500 F.2d at 151-152. No single factor is dispositive. See Pepsi-Cola Bottling Co. v. Commissioner, 528 F.2d 176, 178 (10th Cir. 1975),
aff'g 61 T.C. 564 (1974). Special scrutiny is given in situations where a
corporation is controlled b…
IRCCourt RulingsDec 18, 2012related by meaning
te returns for the subject years. We sustain respondent's
determinations (as amended) as to the imposition of the section 6651(a)(1)
additions to tax. Respondent concedes that the section 6654 addition to tax does not apply
for 1992. As to the remaining years, the record does not establish that any of the
referenced ex…
IRCCourt RulingsDec 16, 1998
…termined it was, and, relying primarily
on Commissioner v. Keystone Consol. Indus., Inc.
, 508 U.S. 152
(1993), argues to the same effect in this proceeding.
Petitioner argues that the transfer was not a prohibited
- 7 -
transaction under section 4975(a). According to petitioner,
the prohibited transaction rules do not…
79 FR 26838 — Tax Treatment of Qualified Retirement Plan Payment of Accident or Health Insurance Premiums IRCFinal Rules (FR)May 12, 2014
…s incurred by the employee, the employee's spouse, the employee's dependents (as defined in section 152 determined without regard to section 152(b)(1), (b)(2), or (d)(1)(B)), or any child (as defined in section 152(f)(1)) of the employee who as of the end of the taxable year has not attained age 27. * * * For the treat…
75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Jul 16, 2010
…e 41628)
As shown in Table 10, total costs for service providers and plan sponsors add up to about $152.5 million for the year 2011.
Table 10—Total Discounted Costs of Proposal
Year
Cost of legal review
Cost of general information disclosure
Cost of investment information disclosure
Cost of qualifying for exemption
Tot…
IRCCourt RulingsApr 26, 1984related by meaning
e instant case, to adhere to the parties’ view of the parameters of the controversy. See Estate of Fusz v. Commissioner, 46 T.C. 214, 215 n. 2 (1966). Section 162(a) allows a deduction for "all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business”. Section 1.…
Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of… IRCNoticesMay 18, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
IRCCourt RulingsJul 22, 1980related by meaning
t acquire a beneficial ownership interest in the ETS trust contributions in 1974.
Because of a concession by respondent with respect to the year 1973, Decision will be entered under Rule 155.
Reviewed by the Court.
Unless otherwise indicated, all statutory references are to the Internal Revenue Code of 1954 as amended …
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
… 125(d)(2)(D)). (4) Dependent. The term dependent generally means a dependent as defined in section 152. However, the definition of dependent is modified to conform with the underlying Code section for the qualified benefit. For example, for purposes of a benefit under section 105, the term dependent means a dependent …
IRCCourt RulingsJul 25, 1974related by meaning
Stebrett, Judge:
The respondent determined deficiencies in petitioners’ Federal income taxes and additions thereto under section 6653 (a), I.R.C. 1954, as follows:
Certain issues haying either been conceded or not raised in the petition, the remaining issues presented for determination -are: (1) Whether $50,000 placed …
T.D. 9166 — Final regulations under section 9801 of the Code provide guidance on the Health Insurance Portability and Accountability Act of 1996 (HIPAA) portability requir… IRCTreasury DecisionsFeb 22, 2005
…ly prohibits the issuer from terminating or failing to offer to renew the insurance (see 45 CFR 146.152). With respect to very small employers, whether group health insurance is subject to the requirements of 45 CFR 146.152 is generally determined by whether the group health plan has two or more participants who are cu…
IRCCourt RulingsDec 19, 2000related by meaning
nership taxable year
* * * [ending after September 3, 1982,] if the partnership, each
partner, and each indirect partner requests such application and the Secretary of the Treasury or his delegate consents to such
application.” Such early application of TEFRA was the case here,
where the parties to the Catamount litiga…
IRCCourt RulingsMay 11, 1998
…in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1998-172
UNITED STATES TAX COURT
RICHARD S. AND BERNICE F. ROBERTS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 467-97. Filed May 11, 1998.
Richard S. Roberts, pro se.
Bradley T. Stanek
, for respo…
IRCCourt RulingsDec 19, 1989related by meaning
ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner.
Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
IRCCourt RulingsMay 8, 2017
…l or family expenses, they are not allowable expenses in computing any net
operating loss. See sec. 172(c) (defining "net operating loss" as the excess of
deductions "allowed" in chapter 1 of the Code over gross income). And perhaps
- 15 -
[*15] more fundamentally section 172(d)(4) "preclude[s] from the computation of
…
IRCProposed Rules (FR)Proposed Feb 18, 2025related by meaning
)-1(b) and 1.263A-1(c)(2).
2 The addition of section 162(m)(3)(C) resulted in pre-ARP section 162(m)(3)(C) being redesignated as section 162(m)(3)(D). 3 This interpretation is consistent with the description of section 162(m)(3)(C) by the Joint Committee on Taxation in General Explanation of the Tax Legislation Enacted…
IRCCourt RulingsDec 19, 1995
Form 1099-R reported
petitioner's Transfer Refund and reflected a gross distribution
of $172,559.14, petitioner's contributions in the amount of
- 6 - $18,112.25, and the taxable amount as the difference or
$154,446.89.
On their Federal income tax return for 1989, petitioners
disclosed the receipt of the Transfer Refun…