78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property IRCFinal Rules (FR)Sep 19, 2013
T
[Removed]
Par. 17.
Section 1.168(i)-7T is removed.
Par. 18.
Section 1.263(a)-0 is amended by:
1. The table of contents introductory text is revised. 2. Revising the section heading and entries to the table of contents for §§ 1.263(a)-1, 1.263(a)-2 and 1.263(a)-3.
3. Adding § 1.263(a)-6 to the table of contents. The r…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
…he DOL and the Department of the Treasury, the DOL's share is 3,241 hours at an equivalent cost of $263,706 annually. The DOL's share of the cost burden is $1,627,679 annually. The summary of burden for DOL and the Department of the Treasury's information collection has also been provided below.
Table 60—DOL and Depart…
IRCCourt RulingsJun 18, 1999related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
IRCCourt RulingsJan 28, 2014★ strong match
her authority that would distinguish the Martin cases from the issue
presented before the Court. Accordingly, petitioners have not met their burden of proving that the weight of the authorities supporting the treatment of the IRA
- 25 -
[*25] distributions is substantial in relation to the weight of the authorities
sup…
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 RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
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…
IRCCourt RulingsFeb 12, 2003related by meaning
(hereinafter the CONTROLLING CASE).
3. All issues involving the above adjustments shall be
resolved as if the petitioner in this case were the same as the taxpayer in the CONTROLLING CASE.
Both stipulations to be bound also provided:
4. A decision shall be submitted in this case when the
decision in the CONTROLLING CAS…
IRCCourt RulingsJan 3, 2011related by meaning
s, earnings, and reasonable charges) pursuant
tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not :
rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant
to Rev. Proc . 2005-25, lsupra.
Held, further, P must include in his gross income
the excess contributiorls pursuan…
IRCPrivate Letter RulingsDec 20, 2013
ements or betterments made to increase the value of
any property.
Section 1.263(a) - 4(d)(1) provides that except as provided in paragraph (f) of this section (relating to the 12 month rule), a taxpayer must capitalize amounts paid to
create an intangible described in this paragraph (d). Section 1.263(a) - 4(d)(2) prov…
IRCCourt RulingsDec 20, 2001related by meaning
penalty under section
6662(a) in order to intimidate petitioners, and (4) the issues
remaining for decision in this case merely represent legitimate, substantive differences of opinion between petitioners and
respondent.
52
On the record before us, we find that, in the event the
computations under Rule 155 establish t…
IRCCourt RulingsAug 22, 2002related by meaning
T.C. Summary Opinion 2002-108
UNITED STATES TAX COURT
CLAUDIA J. DUNN, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5131-01S. Filed August 22, 2002.
Claudia J. Dunn, pro se.
Rollin G. Thorley
, for respondent.
WOLFE, Special Trial Judge
: This case was heard pursuant to
the provisions of secti…
IRCCourt RulingsOct 8, 2003related by meaning
…e carefully scrutinize transactions
between related parties, Maxwell v. Commissioner
, 95 T.C. 107, 116 (1990); C.M. Gooch Lumber Sales Co. v. Commissioner
, 49 T.C.
649, 656 (1968), remanded pursuant to stipulation of the parties
406 F.2d 290 (6th Cir. 1969), and that the service agreement
between Clarkston and J.D. w…
IRCCourt RulingsSep 30, 1985related by meaning
…fying 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.
IRCCourt RulingsJan 12, 1998related by meaning
nice Spetz 8,724
15342-96 Robert C. and Mary D. Borman 16,462
17606-96 Nurit Haramgaal 11,405
17607-96 John S. Husmann and Elinor C. MacKinnon 4,606
1 A notice of deficiency was issued to Alice M. Johnson and her
husband Duaine E. Johnson. Mr. Johnson died on Sept. 1, 1994. An
estat e was not opened for him. Alice M. J…
IRCCourt RulingsOct 2, 1974related by meaning
may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. * * * The cases arising under sec. 267, cited by petitioners, include Fetzer Refrigerator Co. v. United States, 437 F.2d 577 (C.A. 6, 1971); Hyplains Dressed Beef, Inc., 56 T.…
IRCCourt RulingsApr 11, 2012related by meaning
T.C. Memo. 2012-104
JNITED STATES TAX COURT
JERALD W. WHITE AND CLAUDIA K. WHITE, Petitioners y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
DIOGENES HOLDINGS, INC., Petitioner y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 22514-07, 22515-07. Filed April 11, 2012.
David E. Price and Adria S. Price, for p…
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 …
IRCCourt RulingsOct 19, 2010related by meaning
tter of local law and a
State court's determination with regards to such assignment is
not reviewable by this Court);9 Chambers v. Commissioner, supra 9This Court recognizes that in Commissioner v. Estate of
Bosch, 387 U.S. 456, 465 (1967), the Court held that where the
Federal estate tax liability turns upon the chara…