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Go to 143 T.C. 194 (not yet in the library — opens the official source)
89 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …dment, not to the regulatory amendments found in Treasury Decision 5426. 98 Year Statute Regulation 1942 Internal Revenue Code of 1939, ch. 2, sec. 45, 53 Stat. at 25. Sec. 29.45-1, Regulations 111, 26 C.F.R. sec. 29.45-1, at 6141-6142 (Cum Supp. 1944). 1943 Internal Revenue Code of 1939, ch. 2, sec. 45, 53 Stat. at 25…
  2. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …ondent's Remaining Objections Respondent objects that Ms. Ho's report should be excluded under Rule 143(g)(2) because petitioners submitted it to the Court and served it on respondent 22 days before trial, instead of 30 days before as generally required under Rule 143(g)(2). We may, however, excuse untimeliness that is…
  3. T.D. 9694 — These final regulations provide guidance on the application of § 162(m)(6). Section 162(m)(6) limits the allowable deduction for remuneration for services prov…
    IRCTreasury DecisionsOct 6, 2014
    … as of December 31, 2015; $88,996 as of December 31, 2016; $93,446 as of December 31, 2017; and $57,143 as of December 31, 2018. However, for purposes of determining the increase in the present value of the future payments during 2018 (the year of the in-service payment), $57,143 must be increased by $40,000, the amoun…
  4. 29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services
    IRCCourt RulingsJan 30, 1958related by meaning
    ebates for the years 1942, 1943, and 1944 in excess of the amounts determined and paid by the respondent. Decision will be entered for the respondent. The applicable statute Is commonly referred to as the Renegotiation Act of 1943 and Is so designated by the parties. The sections pertinent to this proceeding were enact…
  5. 37 T.C. 78 — Hayward v. Commissioner
    IRCCourt RulingsOct 25, 1961related by meaning
    …riam 202 US 2d 154 (C.A. 6, 1953): “A reading of Section 5(a) of the Act [Wage Stabilization Act of 1942] discloses that the power to prescribe the extent to which an unlawful payment of wages or salaries shall be disregarded by other executive agencies was given by Congress in order to implement the mandate set forth …
  6. T.C. Summary Opinion 2002-87 — Robert C. Jacobsen and Carol S. Jacobsen v. Commissioner
    IRCCourt RulingsJul 11, 2002
    consisting of $4,000 in compensation and $3,194 as employee expenses of Mrs. Jacobsen. The $4,000 was reported as wages by Mrs. Jacobsen on page 1 of the return and thus constituted a “wash”. The $3,194 in employee expenses is allegedly vehicle expense, miscellaneous business expenses, and meals and entertainment expe…
  7. Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t…
    IRCRevenue ProceduresSuperseded Jan 4, 2021
    …Right to status conference 193 .17 How to request status conference 193 .18 Correct format required 194 SECTION 11. WHAT IS THE PROCESS FOR REQUESTING DETERMINATION LETTERS FOR INDIVIDUALLY DESIGNED PLANS? 194 .01 Requesting determination letters 194 .02 Forms 194 .03 Application must include copy of plan and amendment…
  8. 28 T.C. 601 — Edell v. United States
    IRCCourt RulingsJun 10, 1957related by meaning
    OPINION.
  9. Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Dec 30, 2024
    …ased employees 193 .09 Partial terminations 193 .10 Publication 794, Favorable Determination Letter 194 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 194 .01 Scope 194 .02 Complete information required 194 .03 Complete copy of plan and applicable amendments required 194 .04 Separate ap…
  10. Rev. Proc. 2022-4 — This document updates Rev. Proc. 2021-4, 2021-1 IRB 157, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2022
    …tment of certain contributions under § 414(h) 193 .07 Other limits on scope of determination letter 194 .08 Leased employees 194 .09 Partial terminations 194 .10 Publication 794, Favorable Determination Letter 194 SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS? 194 .01 Scope 194 .02 Comp…
  11. 62 T.C. 456; 62 T.C. No. 51 — Latrobe Steel Co. v. Commissioner
    IRCCourt RulingsJul 3, 1974related by meaning
    …o., 14 T.C. 123 (1950). The predecessor of section 404 was originally enacted in the Bevenue Act of 1942 as an amendment to section 23 (p) of the Internal Bevenue Code of 1939. As originally introduced in the House, the bill provided in part as follows:
  12. Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 2, 2024
    …3 .01 Scope of this section 193 .02 Scope of determination letters 193 .03 Design-based safe harbor 194 .04 Governmental plans under § 414(d) 194 .05 Church plans under § 414(e) 194 .06 Tax treatment of certain contributions under § 414(h) 194 .07 Other limits on scope of determination letter 194 .08 Leased employees 1…
  13. 30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner
    IRCCourt RulingsApr 23, 1958related by meaning
    …of section 452. It does not insist that the deduction for officers’ compensation in the fiscal year 1941 was improperly claimed. It does not maintain that any portion of such compensation was unreasonable and therefore disallowable under section 433 (b) (9). Petitioner’s only contention is that the officers’ compensati…
  14. Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru…
    IRCRevenue ProceduresJan 2, 2020
    … prior to time for amending for change in law 193 .06 Restatement not required for terminating plan 194 SECTION 16. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR GROUP TRUSTS? 194 .01 Scope 194 .02 Required information 194 .03 Forms 194 SECTION 17. WHAT ARE THE PROCEDURES FOR FILING A REQUEST FOR A DETERMINAT…
  15. Rev. Proc. 2019-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt Agreements Office. Rev. Proc. 20…
    IRCRevenue ProceduresJan 2, 2019
    …f additional information to interested parties 193 .09 Availability of notice to interested parties 194 PART IIC. PROCESSING DETERMINATION LETTER REQUESTS SECTION 21. HOW DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HANDLE DETERMINATION LETTER REQUESTS? 194 .01 Oral advice 194 .02 Conferences 194 .03 Determination letter…
  16. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008
    …,000 215,802 18,264 234,06 6 12 234,066 25,000 209,066 17,725 226,79 1 13 226,791 25,000 201,791 17,143 218,93 5 14 218,935 25,000 193,935 16,515 210,44 9 15 210,449 25,000 185,449 15,836 201,28 5 16 201,285 25,000 176,285 15,103 191,38 8 17 191,388 25,000 166,388 14,311 180,699 -11 - 18 180,699 25,000 155,699 13,456 1…
  17. 76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner
    IRCCourt RulingsMar 17, 1981related by meaning
    …ommissioner v. Portland Cement Co. of Utah, 450 U.S. _ (1981). H. Rept. 2333,77th Cong., 1st Sess. (1942), 1942-2 C.B. 372,413; S. Rept. 1631, 77th Cong., 2d Sess. (1942), 1942-2 C.B. 541, 606-607. The specific changes made by Congress in 1942 to sec. 165, I.R.C. 1939, included the insertion of the words “or their bene…
  18. Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division…
    IRCRevenue ProceduresJan 2, 2018
    …formation available to interested parties 193 .05 Information to be available to interested parties 194 .06 Special rules if there are fewer than 26 participants 194 .07 Information described in § 6104(a)(1)(D) should not be included 194 .08 Availability of additional information to interested parties 194 .09 Availabil…
  19. 58 T.C. 115 — Doing v. Commissioner
    IRCCourt RulingsApr 25, 1972related by meaning
    ecision will ~be entered for the petitioners. unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
  20. Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government …
    IRCRevenue ProceduresJan 3, 2017
    …ffect of request for § 7805(b) relief 193 SECTION 23. WHAT EFFECT WILL A DETERMINATION LETTER HAVE? 194 .01 May be relied on subject to limitations 194 .02 Scope of reliance on determination letter 194 .03 Effect of subsequent publication of revenue ruling, etc. 194 .04 Effect of subsequent amendment by employer 195 .0…