167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
… value the expected future income from the
property. See, e.g. , Chapman Glen Ltd. v. Commissioner, 140 T.C. 294,
327 (2013) . Income-based methods are not favored when valuing vacant
land with no income-producing history because they are inherently
speculative and unreliable. Ranch Springs, 164 T.C. at 135 (citing
Cha…
IRCCode / StatuteJan 6, 2025
…0 but not more than 120 360 More than 120 but not more than 130 310 More than 130 but not more than 140 260 More than 140 210.
(d)(1)(C) (C) Adjustment for refund feature not applicable For purposes of this paragraph, investment in the contract shall be determined under subsection (c)(1) without regard to subsection (c…
IRCRegulationsMar 14, 2019
…up does not file a consolidated return: (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) A ($10,000) ($140,000) ($150,000) $200,000 1⁄5 $6,000 B (5,000) 105,000 100,000 300,000 3⁄10 9,000 $9,000 $91,000 6/326 × $1,674.85 91,000 C 75,000 175,000 250,000 500,000 1⁄2 15,000 15,000 235,000 6/326 × 4,325.15 235,000 Total 60,00…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
Treas. Reg. § 1.404(a)-13(c) — Contributions of an employer where deductions are allowable under section 404(a) (1) or (2) and also under section 404(a)(3); application of section 404(a)(7). IRCRegulationsMay 18, 2016
…ations, deductions, and carryovers under section 404(a)(1): 1. Contributions paid in year $215 $85 $140 $60 2. Contributions carried over from prior years 0 5 0 20 3. Total deductible for year subject to limitation 215 90 140 80 4. Limitation applicable to year 210 175 120 85 5. Amount deductible for year 210 90 120 80…
IRCRegulationsSep 9, 2016
…s from January 1, 1990, through December 31, 1992, and M's average compensation for this period is $140,000. Thus, the limitation under section 415(b)(1)(B) for the 2008 limitation year is $140,000. As of the end of the 2009 limitation year, the period of M's high-3 consecutive years of service runs from January 1, 200…
IRCRegulationsSep 9, 2016
…acts are the same as in Example 1, except that P's compensation for the current limitation year is $140,000. (ii) The maximum amount of annual additions that may be allocated to P's account in the current limitation year is the lesser of $140,000 (100 percent of P's compensation) or the dollar limitation of section 415…
IRCCourt RulingsJan 26, 1984related by meaning
shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
IRCRegulationsSep 9, 2016
…00,000 limitation by $40,000 (Option 1 for $60,000 + Option 2 for $40,000 + Option 3 for $40,000 = $140,000), it is treated as a nonstatutory option in its entirety.(iv) Assume the same facts as in paragraph (i) of this Example 5, except that on January 1, 2005, E exercises Option 2 and immediately sells the stock in a…
IRCRegulationsSep 9, 2016
…in paragraph (iii) of this Example 11 and the $1,300,000 in liquid assets as of March 31, 2017, or $140,000. The required installment due on April 15, 2017 is therefore $140,000, since this amount is larger than the $50,000 installment otherwise required, but less than the $500,000 needed to increase the plan's FTAP (i…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCRegulationsDec 23, 2021
…ination thereof. Total annual spending means incurred claims, as that term is defined in 45 CFR 158.140, excluding the adjustments specified in 45 CFR 158.140(b)(1)(i), (b)(2)(iv), and (b)(4), and including cost sharing. With respect to prescription drugs, total annual spending is net of prescription drug rebates, fees…
IRCCourt RulingsAug 30, 1999related by meaning
in effect ordered him to
satisfy the increased amount awarded to Ms. Czepiel by making the
IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately
$33,000 on deposit in his IRA's. Respondent counters that the
divorce judgment is not a QDRO and that petition…
Rev. Rul. 2003-124 — Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contribu… IRCRevenue RulingsDec 8, 2003related by meaning
INCOME TAX
Rev. Rul. 2003-122 Rev. Rul. 2003-122
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 1274, 1288, and other sections of the Code, tables set forth the rates for December 2003.
T.D. 9095 T.D. 9095
REG-136890-02
Final, temporar…
IRCCourt RulingsMar 31, 1961related by meaning
ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
IRCRegulationsMar 14, 2019related by meaning
[Reserved]
90 FR 3092 — Automatic Enrollment Requirements Under Section 414A IRCProposed Rules (FR)Proposed Jan 14, 2025
…414(w)(4) and § 1.414(w)-1(b)(3). The burden is as follows:
Estimated number of respondents:
90,000-140,000 plans.
Estimated frequency of responses:
Varies *.
*
The notice would only need to be furnished to unenrolled participants once per year, however, plans have multiple unenrolled participants within a given year.…
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…
Notice 2026-48 — Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions IRCNoticesAug 24, 2026
ch contribution for 2027 is $140, calculated as follows:
Percentage point reduction = 50 percentage points x (($63,000 - $41,000) ÷ $30,000) = 36.6667 Percentage point reduction rounded down to the nearest percentage point = 36
50% - 36 percentage points = 14%
$1,000 x 14% = $140
Taxpayer C’s Saver’s Match contribution…
Rev. Rul. 2004-65 — Post-retirement health benefits; waiver. This ruling holds that an employer has reduced retiree health coverage, within the meaning of section 420(c)(2)(E) of … IRCRevenue RulingsJul 6, 2004related by meaning
INCOME TAX
Rev. Rul. 2004-63 Rev. Rul. 2004-63
Special use value; farms; interest rates. The 2004 interest rates to be used in computing the special use value of farm real property for which an election is made under section 2032A of the Code are listed for estates of decedents.
Rev. Rul. 2004-66 Rev. Rul. 2004-66
Fede…