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77 documents · 0.18sAllIRCERISAPBGCJoint Board
  1. 87 FR 80042 — Exception for Interests Held by Foreign Pension Funds
    IRCFinal Rules (FR)Dec 29, 2022related by meaning
    ef Counsel (International). However, other personnel from the Treasury Department and the IRS participated in their development. ( printed page 80055) List of Subjects in 26 CFR Part 1 Income taxes Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR part 1 is amended a…
  2. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017related by meaning
    ation for which a citation or order was issued under 104(a) of the Mine Act 30 CFR 100.5(C) 7,399 7,520. MSHA Federal Mine Safety & Health Act of 1977 Violation of mandatory safety standards related to smoking standards 30 CFR 100.5(D) 313 318. MSHA Federal Mine Safety & Health Act of 1977 Flagrant violations under 110…
  3. 87 FR 80097 — Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled Qualified Investment Entities
    IRCProposed Rules (FR)Proposed Dec 29, 2022related by meaning
    ). However, other personnel from the Treasury Department and the IRS participated in their development. List of Subjects in 26 CFR Part 1 Income taxes Reporting and recordkeeping requirements Proposed Amendments to the Regulations Accordingly, the Treasury Department and the IRS propose to amend 26 CFR part 1 as follow…
  4. T.C. Memo. 2012-195 — Neil J. Yosinski v. Commissioner
    IRCCourt RulingsJul 12, 2012
    … filed a joint Federal income tax return for 2006. On that return, they repoited the following: 1. $167,433 as the taxabl amount of $442,131 of IRA distributions; 2. $1,255 as taxable wag s; 3. $46 as taxable interest 4. a capital loss of $3,000; 5. total income of $167,014; 6. tax of $27*,505; 7. an additional tax pur…
  5. T.C. Memo. 2013-45 — Alan R. & Toni A. Pinn v. Commissioner
    IRCCourt RulingsFeb 11, 2013
    …h value on Policy # employer amount before loan 12/02, after loan withdrawal was made Ameritas BWS $167,000 $291,329 $98,246 #2477 Ameritas DSC 333,000 547,023 173,200 #2479 The SPD clarified that "[p]olicy cash values may not be pledged or assigned, because the participant has no right to them." -15- [*15] The Trust c…
  6. 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…
  7. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005
    … hereinafter referred to collectively as the trucking company client dispatching functions). Id. at 167. The Court also found that each trucking company client's performing such dispatching functions did not give such trucking company client control over each driver-employee within the meaning of section 31.3121(d)-1(c…
  8. 83 FR 36417 — Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions
    IRCFinal Rules (FR)Jul 30, 2018related by meaning
    ted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business, and no comments were received. Drafting Information The principal author of these regulations is Charles Gorham of the Office of Associate Chief Counsel (Income Tax and Accounting). Other personnel fr…
  9. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    ents of section 2039(c)(3). Due to concessions and in order to reflect petitioner’s claim for an overpayment, Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
  10. T.C. Memo. 1998-321 — Robert J. Hoaglund v. Commissioner
    IRCCourt RulingsSep 9, 1998related by meaning
    s and claims against a debtor's estate. Sec. 507(a)(8) of the Bankruptcy Code provides a priority for unsecured claims of governmental units for taxes measured by income or gross receipts within the time periods set forth therein. by respondent's motion for the reason explained below. However, because no justiciable is…
  11. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973
    … respondent contends that petitioner is not entitled to a deduction for depreciation (under section 167) on the premises donated to the Salvation Army on which it is entitled to a deduction for a charitable contribution. Section 167 allows a deduction for depreciation of property used in the trade or business or held f…
  12. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    foregoing quoted terms are specially defined and used under the "Public Salary Tax Act of 1939" ; 3 . petitioner was not a "person," nor "individual," nor "U .S . person," nor "U .S . individual," nor "taxpayer," nor "non-resident alien," nor any other "legal entity" "made liable for" or "subject to" any "internal reve…
  13. T.C. Memo. 2020-25 — Alvin E. Keels, Sr. v. Commissioner
    IRCCourt RulingsFeb 19, 2020
    …d termination accounts for the years at issue. D. PayPal Respondent determined that petitioner had $167,223 in additional income for 2014 from a PayPal account registered in petitioner's name. Petitioner testified that in 2014 the account was used to receive money from persons buying tickets for a JLF fundraiser and th…
  14. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  15. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    …YE 1991 Receipts: Employer contributions $27,500,000 $42,950,000 $43,800,000 Employee contributions 167,262 99,328 454,699 Cash from insurance companies and redeposits 350,314 1,160,957 -0- Interfund transfers -0- 300,000 -0- Interest 474,509 156,725 100,836 Total receipts 28,492,085 44,667,010 44,355,535 Disbursements…
  16. T.C. Memo. 2005-67 — Laura D. Seidel v. Commissioner
    IRCCourt RulingsMar 31, 2005related by meaning
    se, petitioner has not raised the application of this provision, and petitioner has not presented such credible evidence, nor met all other applicable requirements; therefore, the burden remains with petitioner. 6 Sec. 183(c) provides that an activity is not engaged in for profit if the activity is “other than one with…
  17. 67 T.C. 29 — Federal Land Bank Asso. v. Commissioner
    IRCCourt RulingsOct 6, 1976related by meaning
    or lack of jurisdiction. Appropriate orders will be issued. Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…