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61. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    of eligible individuals, suspended it for 5 years for the vast majority of CSRS employees. The portion of sec. 72(e) involved herein reads as follows: SEC. 72(e). Amounts Not Received as Annuities.— (1) Application of subsection.— (A) In general. — This subsection shall apply to any amount which— (i) is received under …
62. Treas. Reg. § 54.4980H-6(a) — Administration and procedure.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) In general. [Reserved]
63. 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…
64. 89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities
    IRCFinal Rules (FR)Apr 25, 2024related by meaning
    )(i), as contained in 26 CFR part 1, revised as of April 1, 2024. Douglas W. O'Donnell, Deputy Commissioner. Approved: April 2, 2024. Aviva Aron-Dine, Acting Assistant Secretary of the Treasury (Tax Policy). Footnotes 1.  PLR 200923001 (February 26, 2009). Back to Citation 2.   See also STAFF OF THE JOINT COMM. ON TAX'…
65. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    ho conducted petitioner's CDP hearing, a USPS document relating to the notice of deficiency for 2012, and a copy of this Court's order and decision in Wesley v. Commissioner, docket No. 6560-14L. At trial petitioner offered and we admitted into evidence a screen shot of information he had downloaded from the USPS track…
66. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017related by meaning
    ; Bruhwhiler v. Commissioner, T.C. Memo. 2016-18, 111 T.C.M. (CCH) 1071, 1074. Petitioner has repeatedly advanced numerous frivolous positions in this Court. These include assertions that he has no obligation to file Federal income tax returns, that he is the executor of the estate of an artificial person, and that res…
67. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    agreement requires 60 days’ notice, respondent did not issue statutory notices until December 1, 1987, more than 60 days after the date of the letter. Moreover, that respondent did not comply, in exact detail, with his own internal operating procedures does not affect the resolution of the issue presented by petitioner…
68. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    0 and $5,379, respectively; and (4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014 of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a) penalties in writing by making an entry in the Correspondence Examination Automation Case Support…
69. 88 FR 75744 — Federal Independent Dispute Resolution Operations
    IRCProposed Rules (FR)Proposed Nov 3, 2023
    …the No Surprises Act. U.S.C.-Brookings Schaeffer on Health Policy. https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 262.  See Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Cert…
70. 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…
71. 87 FR 52618 — Requirements Related to Surprise Billing
    IRCFinal Rules (FR)Aug 26, 2022
    …s Act.” U.S.C.-Brookings Schaeffer on Health Policy. (March 2021). https://www.brookings.edu/​blog/​usc-brookings-schaeffer-on-health-policy/​2021/​03/​16/​recommendations-for-implementing-the-no-surprises-act/​. Back to Citation 114.  2 U.S.C. 1501 et seq. (1995). Back to Citation 115.  See House Conf. Rep. No. 104-73…
72. 77 FR 37352 — Reporting and Notice Requirements for Deferred Vested Benefits Under Section 6057
    IRCProposed Rules (FR)Proposed Jun 21, 2012related by meaning
    ents or to request a public hearing, Oluwafunmilayo Taylor, (202) 622-7180 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Paperwork Reduction Act The collection of information contained in this notice of proposed rulemaking has been approved by the Office of Management and Budget for review in accordance with the …
73. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    at 568 – 69. Petitioner has not explained why the result should be different here. Petitioner assert s that the placement of section 4973 in the Code i s “irrelevant,” citing section 7806(b) for the proposition that “[n]o inference, implication, or presumption of legislative construction shall be . . . made by reason …
74. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    Court, the two cases were consolidated for hearing on the motions to dismiss. The hearing was held on November 29, 2004, in San Francisco, California. Discussion Section 6033(a)(1) requires an organization exempt from taxation under section 501(a) to file."an annual return, stating specifically the ite s of gross incom…