IRCCourt RulingsDec 31, 1957related by meaning
y its shareholders, partners, or beneficiaries.
Sec. 430 (e) (1).
As stipulated.
Sec. 430 (e) (2) (B).
Sec. 430 (e) (2) (B) (1).
Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsSep 25, 1996
…d that, effective as of
January 1, 1988, MIT 80 would issue an invoice to MPC in the
amount of $301,318.95 for the Contract Renegotiation fee. No
such invoice was issued.
In the agreement, MPC agreed to pay to MIT 80 a balance due
of $1,295,108. This amount included the $301,318.95 that MPC had
agreed to pay in exchang…
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 RulingsOct 10, 2018
…(Chenery II), 332 U.S. 194, 196 (1947) (describing its holding in SEC v. Chenery
Corp. (Chenery I), 318 U.S. 80 (1943)). This means that the SO must clearly set
forth the grounds on which he made his determination, so that we don't have to
guess. See 4 at 196-97. We should not uphold the notice of determination
"simply…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
IRCCourt RulingsJun 10, 1996related by meaning
mount necessary to fund the
benefits payable under section 415 determined at the time of the
contribution in question. Citrus Valley Estates, Inc. v
. Commissioner
, 99 T.C. at 447. The dispute in these cases focuses
on the amounts of benefits payable under section 415 determined
at the time of the contributions in que…
IRCCourt RulingsDec 18, 2012related by meaning
ly for delay, (2) a taxpayer's position is frivolous or groundless, or (3) a
taxpayer unreasonably failed to pursue available administrative remedies. Section 6673 serves in part as "a penalty statute designed to deter taxpayers from
bringing frivolous or dilatory suits". Sauers v. Commissioner, 771 F.2d 64, 68
(3d Cir…
PBGCCode / StatuteJan 6, 2017
…individual who on October 10, 1991, owned directly or indirectly through the application of section 318 of title 26 more than 50 percent of the total voting power of the stock of an affected air carrier;
(a)(14)(C)(ii)(IV) (IV) "successor" means any person that acquires, directly or indirectly through the application o…
89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit IRCFinal Rules (FR)Dec 11, 2024
…section 958(b)(1)) applies in determining ownership of a controlled foreign corporation and section 318(a) applies in determining ownership of other corporations, except that in applying section 318(a)(2)(C), the phrase “10 percent” is used instead of the phrase “50 percent.”
(B) An interest in a partnership (whether d…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
IRCCourt RulingsMar 1, 1999related by meaning
me-generating activities
relating to the items of income, he has satisfied that obligation
through the introduction of predicate evidence. Absent some showing by petitioner as to how the distribution in liquidation
should have been divided between himself and his spouse, there is
no basis for making any apportionment. …
IRCCourt RulingsSep 28, 2011related by meaning
ax of $3,000.60 because
she received.the distributions before she attained age 59-1/2 and
the payments did not qualify for the exceptions set forth in section 72(t) (2) (A) (i) and (v).
Discussion
Summary judgment is intended to.expedite litigation and
avoid unnecessary and expensive trials and may be granted where
the…
T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner IRCCourt RulingsOct 2, 1996related by meaning
g the term "employer reversion"
subsection (c) begins with the words "For purposes of this
section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for
purposes of the income tax
. Indeed this Court has so indicated.
Lee Engineering Supply Co. v. Commissione…
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
…section 958(b)(1)) applies in determining ownership of a controlled foreign corporation and section 318(a) applies in determining ownership of other corporations, except that in applying section 318(a)(2)(C), the phrase “10 percent” is used instead of the phrase “50 percent.”
(ii) An interest in a partnership (whether …
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…763434
4,826,970
$504,465,709
$784,429
2023
4,059,610
4,103,368
1.1763434
4,826,970
504,465,709
735,318
2024
4,059,610
4,103,368
1.1763434
4,826,970 504,465,709
735,318
3 Year Average
4,059,610
4,103,368
1.1763434
4,826,970
504,465,709
751,688
Table 52—DOL's and Department of the Treasury's Summary Table
Year
Estimated…
IRCCourt RulingsOct 19, 2010related by meaning
ense that it caused.to surface a
meritorious section 72(t) issue and resulted in respondent's
I
"Respondent's concession is presumably based upon sec. 72(t) (2) (A) (iv), which provides that the 10-percent additional
tax does not apply to distributions which are "part of a series
of substantially equal periodic payment…
75 FR 64910 — Fiduciary Requirements for Disclosure in Participant-Directed Individual Account Plans ERISAFinal Rules (FR)Oct 20, 2010
…y the rule. According to the 2007 Form 5500 data, the latest complete data available, approximately 318,000 participant-directed individual account plans covering over 58.2 million participants reported compliance with ERISA 404(c). Approximately 165,000 participant-directed individual account plans covering about 13.9…