T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner IRCCourt RulingsJan 21, 1998related by meaning
second notice of
- 12 -
deficiency). Petitioner asserts that the 3-year period of
limitations on assessment and collection with respect to 1992 income tax deficiencies (which are joint deficiencies) and for section 4975
excise taxe s for years before 1993 had expired. Petitioner
characterizes this assertion as a jurisd…
85 FR 6046 — Miscellaneous Corrections, Clarifications, and Improvements PBGCFinal Rules (FR)Feb 4, 2020related by meaning
te for any affected party, file with PBGC a post-distribution certification (PBGC Form 501), completed in accordance with the instructions thereto; or (2)(i) Within 30 days after the last distribution date for any affected party, certify to PBGC, in the manner prescribed in the instructions to PBGC Form 501, that the p…
24 T.C. 460 — Northwest Automatic Products Corp. v. United States IRCCourt RulingsJun 23, 1955related by meaning
a determination of whether we had jurisdiction or not once it should be held that the method prescribed by statute is not the exclusive method. * * * See also, Henry Wilson, 16 B. T. A. 1280 (1929); William M. Greve, 37 B. T. A. 450 (1938); John A. Gebelein, Inc., 37 B. T. A. 605 (1938); Oscar Block, 2 T. C. 761 (1943…
IRCCourt RulingsFeb 9, 2023
…163
Petitioner contends that the Brazilian legal
restrictions met some of these seven requirements.
164
We discuss
162 Title 26 C.F.R. sec. 1.482-1(h)(2)(ii)(A) (2006) requires that the foreign legal
restriction be “publicly promulgated, generally applicable to all similarly situated
persons (both controlled and uncont…
IRCCourt RulingsDec 2, 2010
entitled to a deduction
for one-half of the tax amount. See sec. 164 (f) .
IV. Deductions
Deductions are a matter of legislative grace, and taxpayers bear the burden of proving entitlement to any claimed deduction.
Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84
(1992). Taxpayers are required to identify e…
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…
IRCCourt RulingsMay 22, 2025
United States Tax Court
164 T.C. No. 9
FACEBOOK, INC. & SUBSIDIARIES ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 21 959-16.
1
Filed May 22, 2025.
—————
On September 15, 2010, P entered into a cost
sharing arrangement (CSA) under Temp. Treas. Reg.
§ 1.482-7T with S, its Irish subsidia…
IRCCourt RulingsMar 22, 2007related by meaning
ddition to tax must be
sustained.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or
groundless or the taxpayer has instituted or pursued the
proceeding primarily for delay. Respondent has n…
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
89 FR 54284 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCFinal Rules (FR)Jun 28, 2024related by meaning
olding period raises serious concerns that the family pass-through entity exception is being used inappropriately to circumvent the Disallowance Rule. The Treasury Department and the IRS disagree that the Treasury Department and the IRS lack authority to promulgate an anti-abuse rule. Section 170(h)(7)(G) is a specific…
IRCFinal Rules (FR)Aug 26, 2022
…. Thus, HHS will account for approximately 42,652 hours with an equivalent cost of approximately $2,164,990. DOL and the Department of the Treasury will each account for approximately 21,326 hours with an equivalent cost of approximately $1,082,495.
Table 2—Summary Annual Cost and Burden Regarding Information To Be Sha…
87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
76 FR 13932 — Disclosure of Information to State Officials Regarding Tax-Exempt Organizations IRCProposed Rules (FR)Proposed Mar 15, 2011related by meaning
nt participated in their development.
List of Subjects in 26 CFR Part 301
Employment taxes
Estate taxes
Excise taxes
Gift taxes
Income taxes
Penalties Reporting and recordkeeping requirements
Proposed Amendments to the Regulations
Accordingly, 26 CFR part 301 is proposed to be amended as follows:
PART 301—PROCEDURE AND…
IRCFinal Rules (FR)Dec 18, 2024related by meaning
used only for the purpose of locating the owner of an applicable savings bond;
(2) Must not be used to escheat savings bond ownership to a State; and (3) Must not be released by a State to the public or any third party, unless explicitly approved in writing, in advance, by Treasury.
(d)
Liability.
Treasury is not liab…
IRCFinal Rules (FR)Nov 12, 2020
… non-standard data elements to standard data elements and vice versa.
Back to Citation
208.
45 CFR 164.502(a)(3) and 164.504(e)(2).
Back to Citation
209.
15 U.S.C. 1.
Back to Citation
210.
Id.
Back to Citation
211.
For example,
see84 FR 65464, 65464-65 (Nov. 27, 2019).
Back to Citation
212.
Section 2723 of the PH…
88 FR 60018 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements IRCProposed Rules (FR)Proposed Aug 30, 2023related by meaning
s.gov (preferred) or by telephone
at (202) 317-6901 (not a toll-free number) by at least November 15, 2023.
Statement of Availability of IRS Documents Guidance cited in this preamble is published in the Internal Revenue Bulletin and is available from the Superintendent of Documents, U.S. Government Publishing Office, W…
77 FR 5632 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure ERISAFinal Rules (FR)Feb 3, 2012
… in Table 3 below, total costs for covered service providers and covered plans total approximately $164 million for the year 2012.
( printed page 5652)
Table 3—Total Discounted Costs Rule (Shown With 7 Percent Discount Rate)
Year
Cost of legal review
Cost of general information disclosure
Cost of investment information…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
IRCCourt RulingsFeb 28, 1977
. Rul. 67-164, 1967-1 C.B. 88; Rev. Rul. 69-190, 1969-1 C.B. 131. However, as we shall point out shortly, the present case is sharply distinguishable. In Rev. Rul. 67-164, a trustee distributed to the beneficiaries of an exempt profit-sharing trust the entire amounts standing to their accounts on the date of distributi…