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81. T.C. Summary Opinion 2004-1 — Lawrence K. Mudd v. Commissioner
    IRCCourt RulingsJan 8, 2004
    …ssession of income may nevertheless be considered to have constructively received that income. Sec. 451(a); sec. 1.451-2, Income Tax Regs. The relevant regulations provide that: Income although not actually reduced to a taxpayer’s possession is constructively received by him in the taxable year during which it is credi…
82. T.C. Summary Opinion 2016-64 — Rosella Marie Hill v. Commissioner
    IRCCourt RulingsSep 29, 2016
    … the Court. Petitioner resided in Texas when her petition was timely filed. 2Respondent disallowed $451 of petitioner's claimed student loan interest deduction for 2012. On the basis of our examination of the entire record before us, we find that petitioner did not raise her student loan interest deduction in her petit…
83. I.R.C. § 405 — [§405. Repealed. Pub. L. 98–369, div. A, title IV, §491(a), July 18, 1984, 98 Stat. 848]
    IRCCode / StatuteJan 4, 1995related by meaning
    [§405. Repealed. Pub. L. 98–369, div. A, title IV, §491(a), July 18, 1984, 98 Stat. 848]
84. 39 T.C. 1055 — Cohen v. Commissioner
    IRCCourt RulingsMar 27, 1963
    …the rule of paragraph (1) (B) shall apply (and the rule of paragraph (1) (A) shall not apply). SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under the …
85. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
86. PLR 200914047 — Nonqualified Deferred Compensation
    IRCPrivate Letter RulingsApr 3, 2009
    …. Section 409A supersedes the general rules with respect to constructive receipt that exist under § 451 and under case law. See § 409A(c) (providing that earlier inclusion may be required und er other provisions, and that amounts that are includable under § 409A are not again included in gross income where includable u…
87. 78 T.C. 1187; 78 T.C. No. 83 — Plastic Engineering & Mfg. Co. v. Commissioner
    IRCCourt RulingsJun 30, 1982related by meaning
    enses have any application. Sec. 404(a)(1)(A) permits a deduction "In the taxable year when paid, if the contributions are paid into a pension trust.” Sec. 1.404(a)-7, Income Tax Regs., has not been amended to reflect changes by the Employee Retirement Income Security Act of 1974, Pub. L. 93-406, 88 Stat. 829, 921-923,…
88. 89 FR 32302 — Amendment to Prohibited Transaction Exemption 84-24
    ERISAFinal Rules (FR)Apr 25, 2024
    …t Producers × 1 hour × $165.29)] = $773,313. Back to Citation 86.  The burden is estimated as: [(85,451 small independent producers × 3 hours) + (869 large independent producers × 5 hours)] ≉ 260,967 burden hours. Applying the labor rate of $165.71 is used for a legal professional. The labor rate is applied in the foll…
89. 86 FR 66662 — Prescription Drug and Health Care Spending
    IRCFinal Rules (FR)Nov 23, 2021
    …porting burden is estimated to be 965,340 hours with an equivalent total cost of approximately $137,451,960.[50] The Departments and OPM consider this to be an upper-bound estimate and expect maintenance costs to decline in succeeding years as issuers gain efficiencies and experience in updating, managing, and submitti…
90. T.D. 9932 — Section 162(m)(1) of the Internal Revenue Code generally limits to $1,000,000 the allowable deduction for a taxable year for applicable employee remuneration p…
    IRCTreasury DecisionsJan 19, 2021
    …easury Decision also provides rules regarding cost offsets that apply in certain contexts. 26 CFR 1.451-3 Timing of income inclusion for taxpayers with an applicable financial statement using an accrual method of accounting.; 26 CFR 1.451-8 Advance payments for goods, services, and certain other items. T.D. 9942, page …
91. 115 T.C. No. 19 — Flahertys Arden Bowl, Inc. v. Commissioner
    IRCCourt RulingsSep 25, 2000related by meaning
    lity for the excise taxes and that petitioner was liable for the additions to tax under section 6651(a)(1). Discussion I. Liability Under Section 4975 A. The Statutes Section 4975 was added to the Internal Revenue Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003…
92. T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated …
    IRCTreasury DecisionsDec 6, 2021
    …porting burden is estimated to be 965,340 hours with an equivalent total cost of approximately $137,451,960.50 The Departments and OPM consider this to be an upper-bound estimate and expect maintenance costs to decline in succeeding years as issuers gain efficiencies and experience in updating, managing, and submitting…