IRCCourt RulingsJan 14, 2013★ strong match
…5 13,000 $12,923
1986 15,521 18,764
1987 26,769 29,077
1988 36,000 36,000
1989 36,000 36,000
1990 4,154 4,154
IRCCourt RulingsMar 3, 2016
… to the IRS, the income
was not included on the income tax return: a Form 1099-R reporting the $109,154
IRA distribution from RBS Citizens Bank; a Form 1099-INT, Interest Income,
reporting interest income of $13 from EMC Mortgage Corp.; a Form 1099-DIV,
Dividends and Distributions, reporting taxable dividend income of …
IRCCourt RulingsFeb 9, 2023★ strong match
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
IRCCourt RulingsJul 14, 2005★ strong match
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…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…atements
Pre-Statute
96.1
3.9
0.0
$0
$0
$0
$0
$0
1
51.3
48.7
44.8
53,502,795 18,284,236
4,949,140
5,154,737
81,890,909
2
57.3
42.7
38.8
0
0
0
4,471,532
4,471,532
3
60.2
39.8
35.9
0
0
0
4,139,119
4,139,119
4
61.7
38.3
34.4
0
0
0
3,977,383
3,977,383
5
62.3
37.7
33.8
0
0
0
3,898,691
3,898,691
6
62.7
37.3
33.4
0
0
0
3,860,…
IRCCourt RulingsSep 13, 1990related by meaning
as to utilize the estate tax unified credit to its fullest extent.
Kenneth G. Coveney, for the petitioner.
William H. Quealy, Jr., for the respondent. Nims, Chief Judge. Korner, Hamblen, Cohen, Clapp, Swift, Wright, Parr, and Colvin, JJ., agree with the majority. Chabot, J., concurring *88 in the result. Hamblen and Wh…
IRCCourt RulingsJan 20, 1983related by meaning
g "abuse of tax favored treatment” is to preclude implementation of plans that threaten to increase the cost of the pension system in unintended ways. It is not apparent that Congress intended that actuaries include assumptions as to future cost-of-living adjustments when calculating a current year’s contributions or t…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
… additional performance metrics for private funds—such as:
(1) the public market equivalent (PME); [154]
(2) the modified IRR (MIRR) which adjusts for timing of investment flows;
(3) the multiple on invested capital (MOIC) which measures the total value returned to investor relative to the total capital invested; [155]…
IRCCourt RulingsMar 5, 2018related by meaning
1, 933 (2d Cir. 1932), rev'g 22 B.T.A. 1171
(1931)), aKg T.C. Memo. 1982-209.
With that admonition in mind, we resolve these cases on their particular facts, applying the text of the relevant Code provisions. For the reasons discussed
below, we reject petitioners' broadest argument--that the substance doctrines have
no…
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…ir health-care budgets, with the median share rising from 21 percent in 2021 to 27 percent in 2023.[154]
IRCCourt RulingsApr 25, 1972related by meaning
.B. 27 ; Rev. Rul. 67-213, 1967-2 C.B. 149; Rev. Rul. 68-160, 1968-1 C.B. 167 ; Rev. Rul. 69-254, 1969-1 C.B. 129 ; Rev. Rul. 71-541, 1971-2 C.B. 209. This Court has previously noted that an error committed by a third party contrary to the express desires of a taxpayer should not necessarily control the tax effects of …
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
… PROCEDURE?
152
.01 In general
152
.02 Specific changes
153
PART I. GENERALLY APPLICABLE PROCEDURES
154
>SECTION 3. IN WHAT FORM IS ADVICE PROVIDED BY EMPLOYEE PLANS RULINGS AND AGREEMENTS?
154
.01 In general
154
.02 Letter ruling
154
.03 Closing agreement
154
.04 Determination letter
154
.05 Opinion letter
155
.06 Ora…
IRCCourt RulingsFeb 28, 2024★ strong match
” —not ours. See United
44
States v. Ron Pair Enters., Inc. , 489 U.S. 235, 241 (1989) (quoting Caminetti v. United States, 242 U.S. 470, 485 (1917)). MARSHALL, J. , agrees with this dissent.
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
Rev. Proc. 2020–4
TABLE OF CONTENTS
SECTION 1. WHAT IS THE PURPOSE OF THIS REVENUE PROCEDURE?
154
.01 Purpose of revenue procedure
154
.02 Organization of revenue procedure
154
.03 Other guidance affecting this revenue procedure
154
.04 Updated annually
157
SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 20…
IRCCourt RulingsNov 6, 1962related by meaning
ay pain us, but it cannot alter our decision where unconstitutionality has not been clearly demonstrated.
Decision will be entered for the respondent. Loss of some right, privilege, estate, honor, office, or effects, In consequence of a crime, offense, breach of condition, or other act.
Thls section was originally desi…
IRCCourt RulingsAug 18, 2015
…l years previously. Between 2003
and 2006 petitioners made additional after-tax investments of $346,154 in the
Allstate annuity contract.
In March 2007 petitioners surrendered the Allstate annuity and transferred
the proceeds to a variable annuity from ING USA Annuity & Life Insurance Company (ING). The value of the Al…
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
… revenue procedure
152
.03 Other guidance affecting this revenue procedure
152
.04 Updated annually
154
SECTION 2. WHAT CHANGES HAVE BEEN MADE TO REVENUE PROCEDURE 2018–4?
154
.01 In general
154
.02 Changes made to Revenue Procedure 2018–4
154
PART I. GENERALLY APPLICABLE PROCEDURES
SECTION 3. IN WHAT FORM IS ADVICE PR…
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…
IRCCourt RulingsDec 2, 2010related by meaning
wers v. Commissioner,
24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd.
sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs.
This is especially true in a case involving insurance.
Section 165(a) prohibits a taxpayer from deducting any amount
c…
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…