IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover … IRCTreasury DecisionsMar 23, 2009related by meaning
agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid control number. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law…
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 RulingsDec 16, 1998related by meaning
eof) in the taxable period. The tax imposed by
this subsection shall be paid by any disqualified
person who participates in the prohibited transaction (other than a fiduciary acting only as such).
(b) Additional Taxes on Disqualified Person.--
In any case in which an initial tax is imposed by
subsection (a) on a prohib…
IRCCourt RulingsFeb 18, 1998related by meaning
lure to report any portion of
the distributions. Thus, we find petitioner liable for the
negligence penalty imposed on the portion of the underpayment attributable to the $102,519 not used to purchase the stock.
In keeping with the above holdings,
Decision will be entered
under Rule 155
.
IRCCourt RulingsDec 23, 1996related by meaning
tz v. Commissioner
,
supra
, and Kasey v. Commissioner
, supra
, is also misplaced. In
those cases, we held that the taxpayers constructively received income to which they were entitled but which was garnished and
remitted to judgment creditors. In neither case is there any
indication that the taxpayers disputed their …
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
IRCCourt RulingsOct 9, 1997related by meaning
einafter referred to
as the instant case). The instant case is before the Court on
- 3 -
1
All Code and 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 Procedure.
the parties' cross-motions for partial summary judgment. …
IRCCourt RulingsJun 1, 2009related by meaning
account of the employee's disability ; (4) as part of a serie s
e for life ; (5) to a
employee after separation from service after attainment of ag A substantially equal periodic payments m
55 ; (6) as dividends paid with, respect to corporate stoc k
described in section 404(k) ; (7) to an employee for medica l
or (8)…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
IRCCourt RulingsJun 11, 1996related by meaning
rary purpose has been shown here.
Because we are satisfied that our analysis of section
4980A(e)(2) leads to the conclusion that the Retirement System was a qualified employer plan under section 4980A, we sustain
respondent's determination that petitioner is liable for the 15percent excise tax under section 4980A.
- 11…
IRCCourt RulingsMay 25, 2005related by meaning
s to expedite litigation
and avoid the expense of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burde…
IRCCourt RulingsJan 12, 1998related by meaning
payer receives any amount from a qualified
retirement plan (as defined in section 4974(c)), the
taxpayer's tax under this chapter for the taxable year in which such amount is received shall be increased by
an amount equal to 10 percent of the portion of such
amount which is includible in gross income.
- 9 -
5
See also …
IRCCourt RulingsDec 19, 1995related by meaning
-2503 at 95-2504, 95-1 USTC par. 50,280 (D.
Md. 1995); see also Conway v. United States
, supra
; cf. Wheeler
v. Commissioner
, T.C. Memo. 1993-561.
6 We observe that the
definition of "qualified total distribution" set forth in section
402(a)(5)(E)(i)(II) incorporates the definition of "lump sum
distribution" set fort…
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…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
ment 2009-88 Announcement 2009-88
A list is provided of organizations now classified as private foundations.
Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
IRCCourt RulingsDec 11, 2003related by meaning
oner
, supra
at 780.
11
See id.
at 773.
12
See Eckel v. Commissioner
, T.C. Memo. 1990-174.
13
See, e.g., In re Hatton
, 220 F.3d 1057, 1060 (9th Cir. 2000); In re Hindenlang
, 164 F.3d 1029, 1033 (6th Cir. 1999).
section 6653(a),
3
section 6662,
4
section 6013,
5
section 6033,
6
section 6651(f),
7
section 6511,
8
sect…
IRCCourt RulingsAug 30, 1993related by meaning
ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩
2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…