IRCCourt RulingsAug 13, 1990related by meaning
…C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on proh…
IRCCourt RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003
…ct of 1978 (92 Stat. 2779) added section 457 to the Internal Revenue Code of 1954. On September 27, 1982, final regulations (T.D. 7836, 1982-2 C.B. 91 [47 FR 42335]) under section 457 (the 1982 regulations) were published in the Federal Register. The 1982 regulations provided guidance for complying with the changes to …
IRCCourt RulingsApr 2, 2020related by meaning
…
T.C. 85, 101 (2004); Keller v. Commissioner, 568 F.3d 710, 718 (9th Cir. 2009),
aff'g in part T.C. Memo. 2006-166, and aff'g in part, vacating in part decisions in
related cases. Goldberg resided in Illinois when he filed his petition. Therefore
our decision will not be appealable to the First, Eighth, or Ninth Circui…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
IRCCourt RulingsDec 19, 1995
…fer Refund does not constitute a qualified total
distribution. See Wittstadt v. Commissioner
, T.C. Memo. 1995492; Humberson v. Commissioner
, T.C. Memo. 1995-470; Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 ; Adler v. Commissioner
, T.C.
Memo. 1995-148; Dorsey v. Commissioner
, T.C. Memo. 1995-97; Brown
v. Commissi…
IRCCourt RulingsDec 8, 1987related by meaning
…S, and was received by the Commissioner on Nov. 24, 1978.
See also Brunwasser v. Commissioner, T.C. Memo. 1986-197, affd. 833 F.2d 303 (3d Cir. 1987); Benson v. Commissioner, T.C. Memo. 1985-615. We observe that, in general, where Congress has found it advisable for this Court to consider issues relating to interest, i…