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76 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi…
    IRCRevenue RulingsJul 17, 2006related by meaning
    hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan. ADMINISTRATIVE Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
  2. REG-141075-09 — Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Proposed regulations under section 83 …
    IRCProposed Rules (FR)Proposed Jun 18, 2012related by meaning
    REG-141075-09 Notice of Proposed Rulemaking Property Transferred in Connection with the Performance of Services Under Section 83 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. SUMMARY: This document contains proposed regulations relating to property transferred in connection wi…
  3. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    ead, by giving effect to every word that Congress used in the statute, it protects taxpayers like them with the required “man datory 60-day extension” while the Secretary considers whether and how to exercise his discretion under subsection (a). See Lowe v. SEC , 472 U.S. 181, 207 n.53 (1985); see also Scalia & Garner …
  4. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    f $2,000 under section 6673(a)), af[d, 54 F. App'x 254 (9th Cir. 2002). And his argument that he had no obligation to file a Federal income tax return because he was not a trustee or the executor of an estate--an argument evidently based on the fact that IRS Form 1040 and Code section 1040 happen to share the same four…
  5. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024related by meaning
    e funds ) . 14 [* 14] Moreover, we disagree with petitioner that Larotonda was abrogated by the repeal of section 72(m)(4). Former section 72(m)(4)(A) was replaced by section 72(p) (1)(B), which is substantially similar to section 72(m)(4)(A). 7 In addition, this Court has continued to cite Larotonda as binding precede…
  6. 79 FR 8544 — Shared Responsibility for Employers Regarding Health Coverage
    IRCFinal Rules (FR)Feb 12, 2014related by meaning
    t taxes Estate taxes Excise taxes Gift taxes Income taxes Penalties Reporting and recordkeeping requirements Adoption of Amendments to the Regulations Accordingly, 26 CFR parts 1, 54, and 301 are amended as follows: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows:…
  7. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    T,.C.. 200, 205 (20 06) , af f d. 521 F . 3d 128 9 (10th Cir . - 2008) ; Rogers v . Commi sioner, T.C. Memo. 2001-20, affd. without published opinion 281 F.3d 1278 (5th Cir. 2001) . Additionally, the Commissioner is not r uired to lay out the afactual basis for his determination in the notice of deficiency Ocmulgee" F…
  8. T.C. Memo. 2008-288 — Carl Robert Wagenknecht, Jr. v. Commissioner
    IRCCourt RulingsDec 22, 2008related by meaning
    on ," 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 revenue tax" as used under Title 26 U . S .C . and Title 26 C .F .R . ; 14 . petitioner was not a "person " required to eith…
  9. 89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern
    IRCFinal Rules (FR)May 6, 2024related by meaning
    The electing taxpayer must recapture such amounts on the Federal income tax return described in paragraph (h) of this section. (2) Excessive payments —(i) In general. This paragraph provides rules under section 25E(f) by reference to section 30D(g)(7)(B), which provides that rules similar to the rules of section 6417(…
  10. 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…
  11. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974related by meaning
    may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
  12. 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
    To the extent an eligible taxpayer, as defined in section 6418(f)(2), has determined an increased credit amount under section 45(b)(6) and transferred such increased credit amount as part of a specified credit portion, the obligation to make correction and penalty payments under paragraphs (c)(1)(i) and (ii) of this se…
  13. 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…
  14. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002related by meaning
    s. 6662(d)(2) (B)(ii), 6664(c)(1); secs. 1.6662-3(c), 1.6664-4(a), Income Tax Regs. - 15 - We consider the facts and circumstances in deciding whether the taxpayer acted with reasonable cause and in good faith. Sec. 6664(c)(1); sec. 1.6664-4(b)(1), Income Tax Regs. We conclude that petitioner acted in good faith and wa…
  15. T.C. Memo. 2024-67 — Fabricio Moran v. Commissioner
    IRCCourt RulingsJun 17, 2024related by meaning
    ioner, T.C. Memo. 2013-67, 105 T.C.M. (CCH) 1433, 1439, aff’d , 845 F.3d 971 (9 th Cir. 2017) . An SFR prepared by the IRS pursuant to section 6020(b) is treated as the “return” filed by the taxpayer for this purpose. See § 6651(g). On September 12, 2022, the IRS prepared an SFR setting forth the adjustments discussed …
  16. 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
    lter transaction after May 17, 2006, and before January 1, 2007, the disclosure required by this section shall be filed on or before November 2, 2007. (4) No disclosure. Disclosure is not required with respect to any prohibited tax shelter transaction entered into by a tax-exempt entity on or before May 17, 2006. (e) P…