IRCCourt RulingsFeb 25, 2016
… issued the payment to Strategies under the terms of that contract. It is therefore clear that the $680,000 payment was gross income to
Strategies for 2004.
Petitioner argues that Strategies did not err in failing to include the
$680,000 from Delphi in gross receipts on its Form 1120S for 2004. Petitioner
asserts that …
IRCCourt RulingsFeb 9, 2023★ strong match
…) . Article 45-1,
Regulations 101, was published verbatim in the Federal Register, 4 Fed.
Reg. 616, 680, meaning that the text of article 45- 1 published in the
Federal Register was identical to the text of article 45-1 published in the
pamphlet Regulations 101 Relating to the Income Tax Under the
Revenue Act of 1938 .…
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
…/00/03
Other service: 03/04/21
Sick leave:
.025 service: 23.333333
.03 service:
Average salary: $45,680.80
Total: $26,647.12
Total/month: $2,221.00
Federal Benefit Payment Computation
Birth date: 9/10/46
Hire date: 10/09/77
Freeze date: 06/30/97
Department service: 19/08/22
Other service: 03/04/21
Sick leave:
.025 serv…
75 FR 71047 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCProposed Rules (FR)Proposed Nov 22, 2010
…/00/03
Other service: 03/04/21
Sick leave:
.025 service: 23.333333
.03 service:
Average salary: $45,680.80
Total: $26,647.12
Total/month: $2,221.00
Federal Benefit Payment Computation
Birth date: 9/10/46
Hire date: 10/09/77
Freeze date: 06/30/97
Department service: 19/08/22
Other service: 03/04/21
Sick leave:
.025 serv…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…is no “contribution or
gift” within the meaning of the statute. Hernandez v. Commissioner, 490 U.S. 680, 701 – 02 (1989). To the extent that a taxpayer receives a
quid pro quo, a charitable contribution deduction is permitted only to
the extent that the value of the transferred property exceeds the value
of the benefit…
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…
IRCProposed Rules (FR)Proposed Dec 23, 2025
les ($67,662,000) from the total annual cost for the original 1PB files ($193,680,000): $193,680,000−$67,662,000 = $126,018,000.
Back to Citation
217. Total network costs for transferring new files (300,000 GB) on a quarterly basis are calculated by multiplying the monthly cost per file transfer ($18,795) by the total…
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…
IRCCourt RulingsOct 3, 1995
ent System and the
- 4 -
4
The parties stipulated that the Transfer Refund amounted
to $158,680.9 6
. The documentary record clearly reveals, however, that the correct amount is $158,680.9 8
.
5
So stipulated. The sum of these two amounts equals
$158,446.20, which is the amount of the check dated March 31,
1990, from t…
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 RulingsMar 12, 2008
…156,68 8
20 156,688 25,000 131,688 11,535 143,22 3
21 143,223 25,000 118,223 10,458 128,68 0
22 128,680 25,000 103,680 9,294 112,97 5
IRCCourt RulingsMay 3, 1995
Cumulative Difference
-0-4,184,771 1,856,154 3,504,159 680,612 CD OO <Ji
1,025,021 5,209,792 1,705,633 5,209,792 -0-CD OO <3
Total 5,209,792 5,209,792 Petitioner’s payment to the National Presto VEBA during the 1986 taxable year in the amount of $1,856,154 relates solely to amounts that petitioner had previously deduct…
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’ …
88 FR 76004 — Proposed Amendment to Prohibited Transaction Exemption 84-24 ERISAProposed Rules (FR)Proposed Nov 3, 2023
… written description. This results in an hour burden of 2,000 hours with an equivalent cost of $318,680 in the first year.[57]
( printed page 76020)
Table 7—Hour Burden and Equivalent Cost Associated With the Written Description of Service Provided
Activity
Year 1
Subsequent years
Burden hours
Equivalent burden cost
Bu…
IRCCourt RulingsJul 22, 1980related by meaning
Respondent points out that art. VIII(d) of the Dec. 30, 1974, trust agreement provided for the reversion of all moneys contributed by petitioner to the corporation in the event that petitioner would be unable to secure from the Internal Revenue Service on or before Dec. 81, 1975, approval of the trust as a qualified ta…
IRCCourt RulingsFeb 29, 2012related by meaning
statutory notice of deficiency was issued more than 6 years after
petitioner filed its Form 5530. The statute of,limitations is an affirmative defense that must be specifically pleaded; Petitioner did not raise the statute of;limitations
as an affirmative defense in its pleadings for the taxable year at issue.
Accordin…
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 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 RulingsNov 5, 1999
… participants:
Mortgages -0- -0Other 152,112
-0-
Total investments 152,112
137,270
Total assets 191,680 179,628
Liabilities
Total liabilities -0-
-0-
Net assets 191,680 179,628
The Form 5500 also reports expenses of $20,653 which represented
distribution of benefits directly to participants.
The Schedule B for the year…