IRCCourt RulingsNov 15, 2004related by meaning
lan's participants and beneficiaries. (This
prohibition is not included in the tax provisions,
because of the difficulty in determining an appropriate measure for an excise tax.) [Iji at 309, 1974-3 C.B. at
470.)
* * * * * * *
Following present law with respect to private
foundations, under the substitute where a fiduc…
IRCCourt RulingsDec 17, 1996
…ND OPINION
DEAN, Special Trial Judge
: This case was assigned pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.
1
Respondent determined a deficiency in petitioner's 1992
Federal income tax in the amount of $2,850 and additions to tax
-2under section 6651(a) in the amount of $674 and under s…
IRCCode / StatuteJan 12, 2018related by meaning
(e)(12) (12) Failure to provide correct TIN If— no election under subsection (a)(2) or (b)(2) shall be treated as in effect and subsection (a)(4) shall not apply to such payee.
(e)(12)(A) (A) a payee fails to furnish his TIN to the payor in the manner required by the Secretary, or
(e)(12)(B) (B) the Secretary notifies …
IRCCourt RulingsMay 23, 1996
…pondent.
MEMORANDUM OPINION
CARLUZZO, Special Trial Judge
: This case was heard pursuant
to section 7443A(b)(3) and Rules 180, 181, and 182.
1
Respondent
determined deficiencies in petitioners' 1989, 1990, and 1991
- 2 -
Federal income taxes in the amounts of $1,980, $2,032, and
$2,332, respectively. The issue for deci…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
IRCCourt RulingsJan 8, 1997
…M OPINION
CARLUZZO, Special Trial Judge
: This case was heard pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182. Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue. All
Rule references are to the Tax Court Rules of Practice and…
IRCCourt RulingsDec 23, 1996
…D OPINION
ARMEN, Special Trial Judge
: This case was assigned pursuant
to the provisions of section 7443A(b)(3) and Rules 180, 181, and
182.
1
2
In the notice of deficiency, respondent determined that
petitioner failed to report a distribution from American Capital
Trust Co. in the amount of $2,410.91. Petitioner did n…
IRCRegulationsDec 30, 2016related by meaning
(b) (b) Effective/applicability date. This section is applicable for periods after December 31, 2014.
IRCCourt RulingsNov 7, 1996
…ase was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and
- 2 -
1
Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the taxable year in
issue, and all Rule referenc…
IRCPrivate Letter RulingsSep 14, 2007related by meaning
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
,
IRCCourt RulingsJun 11, 1996
…ase was assigned to Special Trial
Judge Robert N. Armen, Jr., pursuant to the provisions of section
7443A(b)(4) of the Internal Revenue Code of 1986, as amended, and
- 2 -
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule referenc…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
blic hearing on the proposed regulations is scheduled for October 24, 2007. Rev. Rul. 2001-48 and Notice 2006-43 modified.
REG-138707-06 REG-138707-06 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…