IRCCourt RulingsJan 14, 2013related by meaning
sonable compensation and therefore not deductible under
section 162 (and thereby section 404), the 10% section 4972 excise tax applies to
that extent. V. Section 6651(a)(1) and (2) Additions to Tax
Respondent contends that the corporation is liable for section 6651(a)(1)
failure to file additions to tax of $10,050.95 a…
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 RulingsJan 3, 2011related by meaning
,000," and ( ) the cost of
term life insurance on petitioner's life for 2004 of $13,510.
Petitifoner timely filed a petition in this Court.
Discussion Rule 121(a) allows a party to move "for a summary
adjudication in the moving party's favor upon all or any part of
the 1 gal issues in controv rsy." Rule 121(b) directs …
IRCCourt RulingsMar 5, 2018related by meaning
sec. 924 to include gross
receipts from export sales or commission transactions.
24The amount computed under sec. 925(a)(1) could not exceed twice the amount computed under sec. 925(a)(2)--i.e., 46% of the combined taxable income
of the FSC and its related supplier from sale 1 and sale 2. Sec. 925(d).
25The FSC regulat…
IRCCourt RulingsJun 24, 2003★ strong match
…ce or otherwise, for
medical care of the taxpayer, his spouse or a dependent (as
defined in section 152), to the extent that such expenses exceed
7.5 percent of adjusted gross income. As relevant here, section
152(a)(1) defines a "dependent" to mean a taxpayer's father or
sister who received or is treated under section…
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
…3 Areas in which determination letters will not be issued
171
.04 Determination letter applications
172
.05 Review of determination letters
172
SECTION 9. WHAT IS THE GENERAL SCOPE OF A DETERMINATION LETTER?
172
.01 Scope of this section
172
.02 Scope of determination letters
172
.03 Design-based safe harbor
172
.04 Go…
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
.
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
…ce list encouraged
171
.05 Separate application for each single § 414(l) plan
171
.06 Prior letters
172
.07 Plans involving mergers
172
.08 User fees
172
.09 Interested party notification and comment
172
.10 Contrary authority must be distinguished
172
.11 Employer/employee relationship
172
.12 Incomplete applications
…
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 RulingsJan 13, 2003
odial parent. Sec. 152(e)(2).
more than half of whose support during the calendar year is
provided for by the taxpayer, are “dependents”. Sec. 152(a). Section 152(e)(1), however, further provides that if a child
receives more than half of his support during the calendar year
from parents who are divorced or legally sep…
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
… revenue procedure
166
.03 Other guidance affecting this revenue procedure
167
.04 Updated annually
172
.05 Possible future updates related to Appeals review
172
SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2023-4?
172
.01 In general
172
.02 Changes made to Revenue Procedure 2023-4
172
PART I. GENERALLY …
T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.… IRCTreasury DecisionsApr 30, 2007
…date. In this case, the straight life annuity payable under the plan commencing at the same age is $152,619. Because the plan’s factors for actuarial equivalence in this case are the same standardized actuarial factors required to be applied to determine the actuarially equivalent straight life annuity, the actuarially…
REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie… IRCProposed Rules (FR)Proposed Jul 5, 2005
…able. In this case, the straight life annuity payable under the plan commencing at the same age is $152,619. Because the plan’s factors for actuarial equivalence in this case are the same standardized actuarial factors required to be applied to determine the actuarially equivalent straight life annuity, the actuarially…
85 FR 23172 — Unrelated Business Taxable Income Separately Computed for Each Trade or Business IRCProposed Rules (FR)Proposed Apr 24, 2020
…2(a)(6). These commenters noted that the language should not alter the ordering rules under section 172 such that pre-2018 NOLs should be allowed prior to post-2017 NOLs, especially because pre-2018 NOLs remain subject to a carry-forward limitation.
The language of section 512(a)(6) and section 13702(b) of the TCJA do …
IRCCourt RulingsOct 10, 1979related by meaning
r Rule 155.
Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
30 T.C. 96 — Thompson-Hayward Chemical Co. v. Commissioner IRCCourt RulingsApr 23, 1958related by meaning
tment. Sec. 452 (b) (2); sec. 40.452-1, Regs. 130. Here, the petitioner has not maintained an inconsistent position within the 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 compensati…
IRCCourt RulingsJun 14, 2012related by meaning
o. 17204-09
Additions to tax and penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2)' Sec. 6662A
2004 $28,779 $1,179.23 to be determined $9,259.32 2005 83,908 2,131.20 to be determined . 21,855.65
2006 62,339 3,645.68 to be determined 13,879.43
1Respondent explains in the notice of deficiency that the additions to …
IRCCourt RulingsJan 22, 2025
… (2006), aff’d ,
521 F.3d 1289 (10th Cir. 2008).
II. N O L Carryforward Deduction
For 2018, section 172(a) allowed a deduction equal to the sum of
the taxpayer’s NOL carryovers and NOL carrybacks to th e taxable
year.
7
An unused NOL was (and is) generally required to “be carried to
the earliest of the taxable years to…
IRCCourt RulingsOct 29, 2013related by meaning
s amount includes the additional tax of $32,137 under sec. 72(t).
- 27 -
[*27] that the determination of reasonable cause and good faith "is made on a case-by-case basis, taking into account all pertinent facts and circumstances." Sec.
1.6664-4(b)(1), Income Tax Regs.
The parties have agreed in the stipulation of settl…
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
…BLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS?
172
.01 In general
172
.02 Letter ruling
172
.03 Closing agreement
172
.04 Determination letter
172
.05 Opinion letter
173
.06 Oral advice
173
.07 Nonbank trustee approval letters
174
.08 Compliance statement
174
SECTION…