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86 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    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…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  3. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    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 …
  4. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    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…
  5. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    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…
  6. 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…
  7. 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 .
  8. 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 …
  9. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  10. T.C. Memo. 2003-12 — Richard J. Meyer, III v. Commissioner
    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…
  11. 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 …
  12. 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…
  13. 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…
  14. 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 …
  15. 73 T.C. 40 — La Fargue v. Commissioner
    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…
  16. 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…
  17. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    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 …
  18. T.C. Memo. 2025-7 — Sonji Marie Mosley v. Commissioner
    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…
  19. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    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…
  20. 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…