75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac… IRCFinal Rules (FR)Jul 6, 2010related by meaning
to the transaction on or before the first date on which the transaction is required to be disclosed by the person under section 6011.
Special Analyses It has been determined that this Treasury decision is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory assessment is not …
IRCCourt RulingsFeb 18, 1997
…oner
received a distribution (the Transfer Refund) from the Retirement
System in the amount of $174,802.14, which petitioner received in
the form of a check dated November 30, 1989.
Petitioner's Transfer Refund consisted of $11,695.84 in
previously taxed contributions made by petitioner during his
employment tenure wit…
IRCCourt RulingsDec 23, 1981related by meaning
he statute, and there is no authority for allowing an extension of time to amend the plan retroactively.
Decisions will be entered for the respondent. These cases were consolidated for briefing and opinion.
A11 section references are to the Internal Revenue Code of 1954 as amended and in effect during the years in issu…
ERISARegulationsJan 1, 2017related by meaning
For prohibited transaction penalty proceedings, this section shall apply in lieu of § 18.14 of this title.
IRCCourt RulingsNov 1, 2007
…owing information :
- 6 -
Account Number Portfolio Detail Total Valu e
* * * 1315 Mutual funds $289,802 .6 5
* * * 1323 Cash/mutual funds 86,848 .5 2
The Kansas City Tax Clinic, in letters to respondent dated
May 5, 2005, and May 10, 2005, explained that petitioner's
withdrawals from the Bank of America accounts were d…
IRCCourt RulingsAug 13, 1999
…404 first appeared in the Code as
sec. 23(p) of the Revenue Act of 1928, ch. 852, 45 Stat. 791,
799-802. Before adoption of the Revenue Act of 1942, ch. 619, 56
Stat. 798, contributions made to employees' deferred compensation
funds could be deducted either as "ordinary and necessary"
business expenses under sec. 23(a)…
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…
IRCCourt RulingsAug 10, 2000related by meaning
6, 682 (1977); Pawlak v.
Commissioner
, T.C. Memo. 1995-7. Finally, there is no indication
- 8 -
2
Petitioner contends that under IRS Publication 560, Retirement Plans for the Self-Employed, contributions can be
retroactively applied to the previous year if the contributions
are made by the due date of the employer’s r…
Rev. Proc. 2007-71 — Tax-sheltered annuities; written program; public schools; model amendments. This procedure sets forth model amendments that may be adopted in order to satisfy … IRCRevenue ProceduresDec 17, 2007related by meaning
tional provision at Section 2.2(b) and otherwise constitutes an eligible automatic contribution arrangement. See §§ 414(w)(3) and 4979(f) of the Code. 3.7 Protection of Persons Who Serve in a Uniformed Service. An Employee whose employment is interrupted by qualified military service under section 414(u) of the Code or…
T.D. 9294 — Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recip… IRCTreasury DecisionsNov 27, 2006related by meaning
lans.
* * * * *
Par. 9. Section 1.7476-2 is amended by revising paragraph (c)(2) to read as follows:
§1.7476-2 Notice to interested parties.
* * * * * (c) * * *
(2) If the notice to interested parties is delivered using an electronic medium under an electronic system that satisfies the applicable notice requirements of…
80 FR 57709 — Reliance Standards for Making Good Faith Determinations IRCFinal Rules (FR)Sep 25, 2015related by meaning
llection of information must be retained as long as their contents might become material in the administration of any internal revenue law.
Background This document contains amendments to 26 CFR part 53 under chapter 42, subtitle D of the Internal Revenue Code (Code). To avoid certain excise taxes under chapter 42, a p…
IRCCourt RulingsMar 28, 2016
…the SBP made timely premium payments.
- 11 -
[*11] The cost of John Machacek's death benefit was $5,802 in 2005 and $6,543
in 2006.
In addition, the Machacek trust held the Clymer policy, which had no
accumulation value. The Machacek trust did not own any other life insurance
policies on the lives of any other Machacek…
ERISARegulationsApr 8, 2024related by meaning
(a) (a) The rules of procedure set forth in this subpart apply to applications for prohibited transaction exemptions issued by the Department under the authority of:
(a)(1) (1) Section 408(a) of the Employee Retirement Income Security Act of 1974 (ERISA);
(a)(2) (2) Section 4975(c)(2) of the Internal Revenue Code of 19…
75 FR 33992 — Interest and Penalty Suspension Provisions Under Section 6404(g) of the Internal Revenue Code IRCFinal Rules (FR)Jun 16, 2010related by meaning
URE AND ADMINISTRATION
Paragraph 1.
The authority citation for part 301 continues to read in part as follows:
Authority:
26 U.S.C. 7805 * * *.
Par. 2. Section 301.6404-0 is amended by adding an entry for § 301.6404-4 to read as follows:
§ 301.6404-0
Table of Contents.
* * * * *
§ 301.6404-4 Suspension of interest and c…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
cribed in § 4947(a)(2) because it has no amounts in trust for which a deduction was allowed under § 170, 545(b)(2), 642(c), 2055, 2106(a)(2), or 2522. (63) Section 6109.—Identifying Numbers.—The proper assignment or retention of an employer identification number (EIN) in the case of a reorganization within the meaning …
IRCCode / StatuteJan 5, 2023related by meaning
(d)(2)(B)(ii)(I) (I) the relevant facts affecting the item's tax treatment are adequately disclosed in the return or in a statement attached to the return, and
(d)(2)(B)(ii)(II) (II) there is a reasonable basis for the tax treatment of such item by the taxpayer.
(d)(2)(C) (C) Reduction not to apply to tax shelters
(d)(…
88 FR 76660 — Technical Amendments: Special Financial Assistance Withdrawal Liability Condition; SECURE 2.0 Act; and Other Updates PBGCFinal Rules (FR)Nov 7, 2023related by meaning
a speech disability, please dial 7-1-1 to access telecommunications relay services”.
§ 4000.28
[Removed and Reserved]
3. Remove and reserve § 4000.28. PART 4003—RULES FOR ADMINISTRATIVE REVIEW OF AGENCY DECISIONS
4. The authority citation for part 4003 continues to read as follows:
Authority:
29 U.S.C. 1302(b)(3).
§ 40…
IRCCourt RulingsApr 30, 1997
…tegory under which petitioner meant to classify the expense.
inadmissable hearsay.
16
Fed. R. Evid. 802. Therefore, based
upon the record, petitioner has failed to substantiate his
claimed deduction for contributions of property, and the
deduction is accordingly denied.
Schedule C Expenses
Petitioner claimed a deductio…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCRegulationsJan 19, 2017related by meaning
(f)(3) (3) Application of section 1022. The provisions of paragraph (c) of this section relating to section 1022 are effective on and after January 19, 2017.