IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsJun 13, 2012
ed these alternative theories and now argues solely for the application of
sec. 269 to disallow petitioners' $2,969,000 claimed loss deduction.
- 18 - OPINION
Section 269(a) provides that if a taxpayer acquires control of the stock in a
corporation and the principal purpose for the acquisition is the evasion or
avoidan…
IRCCourt RulingsOct 19, 1981
… transactions, as structured, reflected arm’s-length charges for the services performed.
2. Section 269
The second issue is whether respondent properly utilized his authority under section 269 to allocate A & R’s income and deductions to Tahoe City Disposal and Kings Beach Disposal. Section 269 is available—
(a) In Gen…
IRCCourt RulingsMar 5, 2018related by meaning
of petitioners'
transactions.
3¹Purchase and entrance into all contracts were each conditioned on the
other, and so we treat this as one step.
- 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe
harbor from section 482 for the second part of petitioners' transactions--the
commission pa…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…nd (e), 3121(b)(8)(A), and 3401(a)(9).)
(24) Section 111.—See section 3.01(13), above.
(25) Section 115.—Income of States, Municipalities, Etc.—Whether the income of membership organizations established by states exclusively to reimburse members for losses arising from workmen’s compensation claims is excluded from gro…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006
…tain Amounts Paid in Connection with Insurance Contracts.—Whether § 264(c)(1) applies.
(24)
Section 269.—Acquisitions Made to Evade or Avoid Income Tax.—Whether an acquisition is within the meaning of § 269.
(25)
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…tain Amounts Paid in Connection with Insurance Contracts.—Whether § 264(c)(1) applies.
(22)
Section 269.—Acquisitions Made to Evade or Avoid Income Tax.—Whether an acquisition is within the meaning of § 269.
(23)
IRCCourt RulingsDec 23, 2008
…ce contract , he decided to allow the termination . In
response , Northwestern sent petitioner a $1,269 .57 check
representing the difference between the $29,933 . 78 cash value of
the policy and petitioner ' s $28,664 .21 outstanding loan
( including interest accretions) against the cash value .
Northwestern sent peti…
IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
81 FR 7454 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Feb 12, 2016
…:
29 U.S.C. 1302, 1322, 1322b, 1341(c)(3)(D), and 1344.
2. In appendix B to part 4022, add Rate Set 269 to the table to read as follows:
Appendix B to Part 4022—Lump Sum Interest Rates For PBGC Payments
* * * * *
Rate set
For plans with a valuation date
Immediate
annuity rate
(percent)
Deferred annuities
(percent)
On o…
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008
…es on
transactions under the authority given to him in other Code
sections. For example, in section 269 the Commissioner is given
substantial discretionary authority to label a transaction as
engaged in for the principal purpose of tax evasion or avoidance
and to disallow related deductions. The tax "evasion" or
"avoid…
IRCCourt RulingsDec 11, 2003related by meaning
f section 6501,
1
section 6651(a)(1),
2
- 37 -
2
(...continued)
(2003) ; Janpol v. Commissioner
, 102 T.C. 499, 503, 505 (1994);
Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, aff…
IRCCourt RulingsJul 31, 2000★ strong match
red all of petitioners’
arguments for contrary holdings; those arguments not discussed
herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent
necessary to reject or sustain each determination . We also have
considered all of respondent’s arguments a…
IRCCourt RulingsSep 25, 1996
…ware that she had been a leased employee.
Machise considered the amount spent by W & A, some
$3,586,269 in 1987, as the amount of payroll costs incurred under
the employee leasing agreement. In 1987, W & A reported a loss
of $3,586,269, and a separate item of portfolio income of $113.
On their individual income tax ret…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…petition, ultimately contributing to higher costs for self-insured group health plans and patients.[269]
IRCCourt RulingsFeb 9, 2023★ strong match
…omment related to the second
requirement) ......................................................... 269
4. Difficulty of establishing that the remedies
were exhausted ( comment related to the fifth
requirement) ......................................................... 269
5. Payment of dividends and the no -
circumvent…
IRCCourt RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
Notice 2009-22 — Asset valuation under section 430(g)(3)(B) as amended by WRERA. This notice provides interim rules regarding asset valuation methods that are permitted to be u… IRCNoticesApr 6, 2009
…d fair market value at valuation date:($275,386 + $262,282 + $268,849 + $267,848 + $274,436) ÷ 5 = $269,760
This average must be limited so that the actuarial value of assets as of January 1, 2010 satisfies the 90-110 percent corridor rules under § 430(g)(3)(B)(iii). Because the average of adjusted fair market values o…