Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005related by meaning
her § 264(c)(1) applies.
(22)
Section 269.—Acquisitions Made to Evade or Avoid Income Tax.—Whether an acquisition is within the meaning of § 269.
(23) Section 274.—Disallowance of Certain Entertainment, Etc., Expenses.—Whether a taxpayer who is traveling away from home on business may, in lieu of substantiating the act…
IRCCourt RulingsAug 27, 2026
…indicia or “badges” of
fraud to find circumstantial evidence of fraud. See Niedringhaus, 99 T.C.
at 211; DiLeo , 96 T.C. at 875. These badges of fraud include , as
potentially relevant here, understating income; failing to maintain
adequate records; offering implausible or inconsistent explanations of
behavior; failing…
T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred… IRCTreasury DecisionsFeb 6, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-7 Rev. Rul. 2006-7
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for February 2006.
T.D. 9238 T.D. 9238
Temporary and proposed regul…
83 FR 57536 — Religious Exemptions and Accommodations for Coverage of Certain Preventive Services Under the Affordable Care Act IRCFinal Rules (FR)Nov 15, 2018related by meaning
18071, 18082, 26 U.S.C. 36B, and 31 U.S.C. 9701); and Public Law 103-141, 107 Stat. 1488 (42 U.S.C. 2000bb-2000bb-4).
List of Subjects
26 CFR Part 54 Excise taxes
Health care
Health insurance
Pensions
Reporting and recordkeeping requirements
29 CFR Part 2590
Continuation coverage
Disclosure
Employee benefit plans
Grou…
Notice 2023-75 — Section 415 of the Internal Revenue Code (the Code) provides for dollar limitations on benefits and contributions under qualified retirement plans. Section 415… IRCNoticesNov 20, 2023related by meaning
ts. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).
EXCISE TAX
REG-115762-23, page 1262. This document sets forth proposed rules related to the fees established by the No Surprises Act for the Federal independent dispute resolution (IDR) process, as establis…
PBGCRegulationsAug 8, 2022related by meaning
(g) (g) If any provision in this part is held to be invalid or unenforceable by its terms, or as applied to any person or circumstance, or stayed pending further agency action, the provision will be construed so as to continue to give the maximum effect to the provision permitted by law, unless such holding will be one…
77 FR 37352 — Reporting and Notice Requirements for Deferred Vested Benefits Under Section 6057 IRCProposed Rules (FR)Proposed Jun 21, 2012related by meaning
Document Headings
Document headings vary by document type but may contain
the following:
the agency or agencies that issued and signed a document
the number of the CFR title and the number of each part
the document amends, proposes to amend, or is directly
related to
the agency docket number / agency internal file numb…
89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02 ERISAFinal Rules (FR)Apr 25, 2024related by meaning
within a foreign country that is included on the Department of Commerce's list of “foreign adversaries” that is codified in 15 CFR 7.4 as amended); or (2) Found or determined in a final judgment or court-approved settlement in a Federal or State criminal or civil court proceeding brought by the Department, the Departme…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
om tax under section 897(l), regardless of the amount of unrealized gain in Property A as of November 1, 2016.
(f)
Applicability date
—(1)
In general. Except as otherwise provided in paragraph (f)(2) of this section, this section applies to a disposition of a United States real property interest, or a distribution desc…
86 FR 66662 — Prescription Drug and Health Care Spending IRCFinal Rules (FR)Nov 23, 2021related by meaning
notice that a provider, facility, or provider of air ambulance services has initiated the Federal IDR process, upon sending or receiving such notice. (2) The Director will coordinate with the Departments in resolving matters under 26 CFR 54.9816-8T(c)(4)(vii)(A)(
1), 29 CFR 2590.716-8(c)(4)(vii)(A)(
1), or 45 CFR 149.…
IRCCourt RulingsJul 31, 2000
… for the
respective years from 1991 through 1993: Dr. and Ms.
Hirshkowitz-–$254,051, $136,678, and $211,120; Dr. and Ms. Desai-
–$122,750, $42,056, and $55,000; Dr. and Ms. McManus-–$20,000,
$17,921, and $18,186; and the Estate of Steven Sobo, Deceased,
- 60 -
20
In summary, respondent determined that the disallowed
co…
IRCCourt RulingsSep 14, 1993related by meaning
nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if—
(i) such lump sum distribution is received by an ind…
IRCCourt RulingsAug 27, 2008
…red to make
an annual payment under section 6654(d)(1)(B) . See Wheeler v .
Commissioner , supra at 211 . The amount of any required annual
- 10 - payment is the lesser of (1) 90 percent of the tax shown on the
individual's return for the year or, if no return is filed, 90
percent of his or her tax for such year, or (2…
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…
IRCCourt RulingsNov 12, 1997
…ordingly
increased petitioner's taxable income by $40,355. Moreover,
respondent disallowed all but $211 of petitioner's $33,943
investmen t interest expense deductions on the basis that
petitioner's offsetting investment income was only $211.
Respondent also determined that petitioner had only substantiated
$29,443 of …
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008related by meaning
ven such regulations is well
known. See, e.g., Chevron U.S.A., Inc. v. Natural Res. Def.
Council, Inc., 467 U.S. 837 (1984); Swallows Holdino, Ltd. v. Commissioner, 515 F.3d 162 (3d Cir. 2008), vacating 126 T.C. 96
(2006).
The delegation Congress made to the Secretary in section
404(k)(5) (A), however, is particularly …