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81. T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred…
    IRCTreasury DecisionsFeb 6, 2006related by meaning
    idance concerning the requirements for designated Roth contributions under qualified cash or deferred arrangements. EMPLOYMENT TAX T.D. 9239 T.D. 9239 Final, temporary, and proposed regulations under section 6011 of the Code relate to the time for employers to file returns and make deposits under the Federal Insurance …
82. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
83. T.C. Memo. 2012-13 — John K. Goyak & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 11, 2012
    …enditure satisfies each of these requirements is a question of fact. See Commissioner v. Heininger, 320 U.S. 467, 475 (1943). Purchasing insurance for the benefit of an employee is, in many circumstances, an ordinary and necessary business expense deductible under section 162(a). See Curcio v. Commissioner, supra; Frah…
84. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …enditure satisfies each of these requirements is a question of fact. See Commissioner v. Heininger, 320 U.S. 467, 475 (t1943). Petitioners argue that Diogenes' contributions to the xélan 419 plan and the Millennium plan satisfy the requirements of section 16 and are thus deductible under section 162(a). Petitioners con…
85. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …id at beginning of year 29,089,779 6,539,180 10,915,099 11,822,329 b. Interest to yearend 1,599,938 320,420 392,944 425,604 c. Paid at yearend [a + b] 30,689,717 6,859,600 11,308,043 12,247,933 1 In 1991, this is the present value of active benefits only, excluding the 1991 net benefit costs. 2 In 1991, this includes t…
86. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    er consents to the immediate assessment and collection of the tax and the interest to which the tax relates. Aguirre v. Commissioner, 117 T.C. at 327. Section 6404(e)(1) provides that the IRS may abate assessed interest under certain conditions that we discuss infra part III. Section 6404(e)(2) provides that the IRS ma…