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86 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    ension, profit-sharing, or annuity plan, or other plan deferring the receipt of compensation, subsection (a) shall apply as if there were such a plan. “Except where such authority is expressly given by this title to any person other than an officer or employee of the Treasury Department, the Secretary shall prescribe a…
  2. 42 T.C. 993 — Barrett v. Commissioner
    IRCCourt RulingsAug 31, 1964
    … meaning of the income tax law, that such a policy is a capital asset within the meaning of section 1221, and that gain on the exchange of a capital asset held for more than 6 months is long-term capital gain under section 1222 (3). This argument is similar to the contention which has been rejected in numerous cases th…
  3. 76 FR 52259 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code
    IRCFinal Rules (FR)Aug 22, 2011related by meaning
    01.6404-4. * * * * * § 301.6404-4 Suspension of interest and certain penalties when the Internal Revenue Service does not timely contact the taxpayer. (a) Suspension. (1) In general. (2) Treatment of amended returns and other documents. (i) Amended returns filed on or after December 21, 2005, that show an increase in t…
  4. 58 T.C. 940 — Funkhouser v. Commissioner
    IRCCourt RulingsSep 11, 1972
    …since they would have received the direct benefits of these payments. N. Loring Danforth, 18 B.T.A. 1221. Although the conditions are not quite the same here, the distinction is so slight as not to be material. It is true that the present policies were taken out by and are the property of the trustee, to whom all the p…
  5. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025related by meaning
    one fluent in English knows that the word ‘includes’ cannot be assumed to mean ‘includes only .’ . . .”) ; Waltne r , 107 T.C.M. (CCH) at 1201 (citing United States v. Lat ham , 754 F.2d 747, 750 (7th Cir. 1985) ) . In sum, petitioner’s arguments have been rejected by the courts in hundreds of cases, and we will not di…
  6. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987
    … Cir. 1982); Cutaiar v. Marshall, 590 F.2d 523, 529 (3d Cir. 1979); Donovan v. Walton, 609 F. Supp. 1221, 1246 (S.D. Fla. 1985); McDougall v. Donovan, 552 F. Supp. 1206, 1215 (N.D. Ill. 1982); Freund v. Marshall & Ilsley Bank, 485 F. Supp. 629, 637 (W.D. Wis. 1979); Marshall v. Kelly, 465 F. Supp. 341, 354 (W.D. Okla. …
  7. 76 FR 13932 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations
    IRCProposed Rules (FR)Proposed Mar 15, 2011related by meaning
    (a), which is the general prohibition on the disclosure of returns and return information, except as authorized by Title 26 of the United States Code; (2) section 6103(p)(3), which requires the IRS to maintain permanent standardized records of all requests for inspection or disclosure of returns or return information u…
  8. IRCCourt RulingsMar 30, 1978
    …ptance of petitioner’s argument on the highly compensated contention. When property other than sec. 1221 property is involved.
  9. 84 FR 25209 — Withholding on Certain Distributions Under Section 3405(a) and (b)
    IRCProposed Rules (FR)Proposed May 31, 2019related by meaning
    persede the guidance in Notice 87-7 for payors of designated distributions with respect to their duty to withhold under sections 3405(a)(1) or (b)(1). A. Payees With a Military or Diplomatic Post Office Address For purposes of section 3405(e)(13)(A), the proposed regulation treats an APO, FPO, or DPO address as an addr…
  10. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
  11. 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
    …day on which the owner entered into the hedge. The identification must meet the requirements of § 1.1221-2(f)(4) and must include the following information— (i) The date on which the hedge is entered into by the owner of the hedged QBU and the date on which the hedge is identified as a section 987 hedging transaction; …
  12. 138 T.C. No. 7 — Research Corporation v. Commissioner
    IRCCourt RulingsFeb 29, 2012related by meaning
    urd result. We agree. ,It is a well-established canon of statutory . interpretation that "'identical words used in different parts of the same act are intended to have the same meaning."' United States Nat'l Bank of Or: v. Indep. Ins. Agents of Am:, Inc., 508 U.S. 439/460 (1993) (quoting Commissioner v. Keystone Consol…
  13. 88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCProposed Rules (FR)Proposed Nov 20, 2023
    …bandonment (other than in the ordinary course of business) of a capital asset as defined in section 1221 of the Code (determined without the application of any other rules of law) and any item from the disposition or abandonment (other than in the ordinary course of business) of property used in a trade or business as …
  14. Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24…
    IRCNoticesJun 1, 2026related by meaning
    The Tax Court denied the IRS’s motion to dismiss the case for lack of jurisdiction. In a unanimous opinion, the Tax Court held that section 7508A(d) (as amended in 2019) unambiguously provided for an automatic and mandatory postponement period that incorporated all of the acts referenced by section 7508A(a), from the e…
  15. Treas. Reg. § 301.6652-1(f) — Failure to file certain information returns.
    IRCRegulationsDec 19, 2016related by meaning
    (f) (f) Showing of reasonable cause. The amount imposed by subsection (a), (b), or (c) of section 6652 shall not apply with respect to a failure to file a statement within the time prescribed if it is established to the satisfaction of the district director or the director of the Internal Revenue Service Center that su…
  16. 89 FR 12955 — Management of Federal Agency Disbursements
    IRCFinal Rules (FR)Feb 21, 2024related by meaning
    l.treasury.gov, or Rebecca Saltiel, Senior Counsel, at (202) 874-6648 or Rebecca.Saltiel@fiscal.treasury.gov. SUPPLEMENTARY INFORMATION: I. Background In 1998, Fiscal Service issued a final rule, codified at 31 CFR part 208 (part 208), to implement the requirements of 31 U.S.C. 3332, as amended by section 31001(x)(1) o…
  17. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995
    …ivan, 932 F.2d 1273, 1278 (9th Cir. 1991); Combined Communications v. U.S. Postal Service, 891 F.2d 1221, 1223 (6th Cir. 1989); Tennessee v. Herrington, 806 F.2d 642 (6th Cir. 1986); Tierney v. Schweiker, 718 F.2d 449, 454 (D.C. Cir. 1983). Petitioner’s position would further only the first goal, i.e., to facilitate th…
  18. 29 C.F.R. § 2570.133 — Parties, how designated.
    ERISARegulationsJan 1, 2017related by meaning
    For 502(c)(7) civil penalty proceedings, this section shall apply in lieu of § 18.10 of this title.
  19. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    whether the regulation harmonizes with the plain language of the statute, its origin, and its purpose. A regulation may have particular force if it is a substantially contemporaneous construction of the statute by those presumed to have been aware of congressional intent. If the regulation dates from a later period, th…
  20. I.R.C. § 6652(c)(1)(D) — Failure to file certain information returns, registration statements, etc.
    IRCCode / StatuteJan 24, 2020related by meaning
    (c)(1)(D) (D) Public inspection of applications for exemption and notice of status In the case of a failure to comply with the requirements of section 6104(d) with respect to any exempt status application materials (as defined in such section) or notice materials (as defined in such section) on the date and in the mann…