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…
88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations IRCProposed Rules (FR)Proposed Nov 20, 2023related by meaning
hearing, contact Vivian Hayes at (202) 317-6901 (not a toll-free number) or by email to
publichearings@irs.gov
(preferred).
SUPPLEMENTARY INFORMATION: Background
I. Overview
This document contains proposed regulations that would amend the Income Tax Regulations (26 CFR part 1) under sections 170 and 706 of the Internal…
IRCFinal Rules (FR)Mar 18, 2015
…art 54 continues to read in part as follows:
Authority:
Authority: 26 U.S.C. 7805. * * *
Section 54.9831-1 also issued under 26 U.S.C. 9833; * * *
Par 2.
Section 54.9831-1 is amended by adding paragraph (c)(3)(vii) to read as follows:
§ 54.9831-1
Special rules relating to group health plans.
* * * * *
(c) * * *
(3) * *…
IRCCourt RulingsJun 11, 1996related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respond…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019related by meaning
er means and the transferor was, in fact, a foreign person, then the transferee is subject to the liability imposed by section 1445 and § 1.1445-1(e). (i) A transferee is in no event required to rely upon other means to ascertain the non-foreign status of the transferor and may demand a certification of non-foreign sta…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
88 FR 11754 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCFinal Rules (FR)Feb 23, 2023related by meaning
dent of Documents, U.S. Government Publishing Office, Washington, DC 20402, or by visiting the IRS website at
http://www.irs.gov.
Drafting Information The principal author of these final regulations is Casey R. Conrad of the Office of the Associate Chief Counsel (Procedure and Administration). Other personnel from the …
87 FR 80042 — Exception for Interests Held by Foreign Pension Funds IRCFinal Rules (FR)Dec 29, 2022related by meaning
ification of non-foreign status must be signed under penalties of perjury and must state—
(
i) That the interest-holder is not a foreign person; and
( ii) The interest-holder's name, identifying number, home address (in the case of an individual), or office address (in the case of an entity), and place of incorporation…
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…
IRCRegulationsJun 17, 2024
…enrollment date does not change. Excepted benefits means the benefits described as excepted in § 54.9831(c). First day of coverage means, in the case of an individual covered for benefits under a group health plan, the first day of coverage under the plan and, in the case of an individual covered by health insurance co…
IRCRegulationsSep 13, 2021
…enrollment date does not change. Excepted benefits means the benefits described as excepted in § 54.9831(c). First day of coverage means, in the case of an individual covered for benefits under a group health plan, the first day of coverage under the plan and, in the case of an individual covered by health insurance co…
IRCCourt RulingsJun 1, 2009related by meaning
account of the employee's disability ; (4) as part of a serie s
e for life ; (5) to a
employee after separation from service after attainment of ag A substantially equal periodic payments m
55 ; (6) as dividends paid with, respect to corporate stoc k
described in section 404(k) ; (7) to an employee for medica l
or (8)…
IRCRegulationsNov 22, 2024
…al) but not more than 50 employees on business days during the preceding calendar year. See section 9831(a) and § 54.9831-1(b), which provide that this section (and certain other sections) does not apply to any group health plan for any plan year if, on the first day of the plan year, the plan has fewer than two partic…
IRCCourt RulingsFeb 9, 1998related by meaning
tled "Statement in Lieu of Return"
until after the notice of deficiency was mailed to him.
- 18 -
We believe that petitioner submitted these documents primarily to advance his frivolous tax protester arguments rather
than to report honestly and accurately his income to respondent.
He purposefully did not keep records o…
IRCCourt RulingsSep 22, 1998related by meaning
15 of the year following the
taxable year, for which no deduction is allowed with respect to
the contribution, are not taxable upon distribution. Sec. 408(d)(4); Childs v. Commissioner
, T.C. Memo. 1996-267.
Petitioner was employed by the Tribe in Indian fishingrights-related activity. Payments to petitioner for such I…