IRCCourt RulingsSep 24, 2007
…41 deficiency for petitioner's 2002 taxable
year . The issues for decision are :
(1) Whether a $168,355 pension distribution to petitioner in
2002 pursuant to a qualified domestic relations order (QDRO) is
includable in petitioner's 2002 taxable income ;
(2) whether $8,119 .20 of the $9,552 in Social Security
benefits …
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
…engages in commercial activity with respect to the real property interest transferred. (28) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
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 RulingsFeb 9, 2023related by meaning
rticle 12 of Law
No. 4,131, of September 3, 1962.
ANTONIO DELFIM NETTO
The English portion of Exhibit 31 - J (Portaria 60/94 ) is:
MF Ordinance No. 60 D.O.U.: 2/01/1994
The MINISTER OF FINANCE, in exercise of its statutory
duties, taking into view the provisions of art. 50 of Law No.
8,383, of December 30, 1991 and Ord…
IRCCourt RulingsFeb 6, 2024
…ioner ,
50 T.C. 585, 592 (1968 ) ) ; accord Benes v. Commissioner, 42 T.C. 358, 381
(1964), aff’d , 355 F.2d 929 (6th Cir. 1966) ; see also Corliss, 281 U.S.
at 378; Treas. Reg. § 1.451-2(a). As discussed below, t his Court has
consistently applied the constructive receipt doctrine in cases where the
taxpayer’s assets …
IRCRegulationsJan 19, 2017
…plicable with respect to stock acquired by a distribution or an exchange to which section 305, 354, 355, 356, or 1036 (or so much of section 1031 as relates to section 1036) applies. Stock so acquired shall, for purposes of sections 421 through 424, be considered as having been transferred to the individual upon his ex…
IRCProposed Rules (FR)Proposed Dec 23, 2025
s in an annual storage savings of roughly $57,355,200 [210]
for the 300 third-party developers and other files users based on file-size optimizations. However, because these proposed rules also shift the reporting frequency from monthly to quarterly, total storage needs and corresponding savings would be reduced accord…
IRCCourt RulingsDec 18, 2012★ strong match
0- (1,561) -0-
(3,763) (2,116) -0-
-0- (1.461) -016,087 15,355 19,542
Respondent determined that each petitioner realized one-half of the total rental income for 1995, 1996, and 1997. These amounts are as follows:
1995 1996 1997
Deposited rent $17,908 $41,810 $2,730
Additional rent 16,087 15,355 19,542
Total rent 33,99…
IRCCourt RulingsJan 3, 2011
…of thee$36,000 was credited towards the
cash value of petitioner' s life insurance policy. The $17, 355
excess contribution was not credited toward the cash value of the
life insurance policy covering petitioner discussed in the PERC
valuation above . Consequently, the inclusion of the excess
contribution in petitioner…
IRCCourt RulingsFeb 28, 2024related by meaning
stituting a 6-year period in lieu of the 3-year
period otherwise referred to in such subsection.
(D) Exception for certain acquisitions of property. — In the case of any tax imposed by section 4973 that is attributable to acquiring property for less than fair market
value, subparagraph (A) shall not apply.
Section 313(…
IRCCourt RulingsJul 31, 2000
…of that year, the conversion credit balance was $124,364.78 ($77,954.39 + $53,150 - $12,095.03 + $5,355.42); the
$5,355.42 is the interest of 4.5 percent earned on the conversion
credit balance (($124,364.78 - $5,355.42) x 4.5% = $5,355.42)).
Of the conversion credit balance, $112,239.22 could have been
transferred at …
90 FR 4192 — Voluntary Fiduciary Correction Program ERISAFinal Rules (FR)Jan 15, 2025
…st savings
(A)
(B)
(A−B)
Traditional VFC Program (annual)
$765,570
$215,876
$549,693
SCC (annual)
355,910
−355,910
VFCP Exemption (annual)
120,236
120,236
0
Total (annual)
885,806
692,023
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…t by the inflation adjustment factor for 1983 of 2.35483, which resulted in a maximum penalty of $2,355. The amount of the increase from $1,000 to $2,355 is $1,355, which is less than the statutory cap of 150 percent of the existing $1,000 penalty, which is $1,500; accordingly, the amount of the increase is not limited…
IRCCourt RulingsJan 14, 2013related by meaning
Mr. Villasenor was injured on or about May 13, 2000. Although the
file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's
compensation claim, Ms. Strick's name does not appear on any of the documents,
and she did not…
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
…engages in commercial activity with respect to the real property interest transferred.
(29) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
88 FR 75890 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAProposed Rules (FR)Proposed Nov 3, 2023
… disclosure + $16,085 to prepare and send disclosures + $3,072 for material and postage costs) = $9,355,525. The cost in subsequent years is estimated as: ($8,336,244 for the rollover disclosure + $16,085 to prepare and send disclosures + $3,072 for material and postage costs) = $8,355,401. Note, the total values may n…
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…
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
…engages in commercial activity with respect to the real property interest transferred.
(29) Section 355.—Distribution of Stock and Securities of a Controlled Corporation.—Whether the active business requirement of § 355(b) is met when, within the 5-year period described in § 355(b)(2)(B), a distributing corporation acq…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
82 FR 60308 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 20, 2017
…
2025
742
742
3,134
3,134
2026
759
759
3,206
3,206
2027
777
777
3,280
3,280
2028 or later
794
794
3,355
3,355
1
Table II-A.
2
Table II-B.
3
Table II-C.
* * * * *
Issued in Washington, DC, by:
Daniel S. Liebman,