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 RulingsDec 29, 2005related by meaning
as in effect in 2001 provides
in pertinent part:
2. (a) In determining the taxable income of an
individual who renders personal sérvices and who is a resident of a Contracting State but not a national of
that State, contributions paid by, or on behalf of,
such individual to a pension or other retirement
arrangement th…
IRCCourt RulingsJan 12, 1998related by meaning
tely $1,026,855 in U. S.
currency deposited into various bank accounts during the period
January 19, 1988, through August 23, 1989, in violation of 31 U.S.C. sections 5324(3) and 5322(a) (1988); and (3) 10 counts
alleging violations of customs reporting requirements.
On January 9, 1992, petitioner entered into a plea a…
Notice 2005-1 — This notice provides general and transitional guidance relating to new section 409A of the Code, added as part of the American Jobs Creation Act of 2004. Secti… IRCNoticesJan 10, 2005related by meaning
with Respect to Taxes on Income signed at Washington, D.C., on October 2, 1996.
The text of the Agreement is as follows:
COMPETENT AUTHORITY AGREEMENT The competent authorities of the United States and Switzerland hereby enter into the following agreement (“the Agreement”) regarding the qualification of certain U.S. an…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
….C. 714, 719 – 20 (1982), aff’d , 731 F.2d 1417 (9th
Cir. 1984); Markosian v. Commissioner, 73 T.C. 1235, 1244 – 45 (1980);
Saccato v. Commissioner, T.C. Memo. 2023-96, at *8. Whether a trust
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
ment 2009-88 Announcement 2009-88
A list is provided of organizations now classified as private foundations.
Announcement 2009-90 Announcement 2009-90 The IRS has revoked its determination that Twenty First Century World — TEMENOS of San Rafael, CA, qualifies as an organization described in sections 501(c)(3) and 170(c…
167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner IRCCourt RulingsJul 15, 2026
…iry begins and ends
with the statute ’ s plain language. ” Shockley v. Commissioner, 686 F.3d
1228, 1235 (11th Cir. 2012), rev’g and remanding T.C. Memo. 2011-96.
Section 6662 is not ambiguous with respect to the issue in dispute. The
statutory text is clear that the adequate disclosure exception does not
apply to the …
IRCCourt RulingsNov 17, 2016
…ily the decisions by this Court in Vinson & Elkins v.
Commissioner, 99 T.C. 9 (1992), aff'd, 7 F.3d 1235 (5th Cir. 1993), and Citrus
Valley Estates, Inc. v. Commissioner, 99 T.C. 379 (1992), aff'd in part, remanded
in part, 49 F.3d 1410 (9th Cir. 1995), for putative support for its position on
actuarial equivalence. Fo…
IRCCourt RulingsMar 5, 2018
…e
related, so heightened scrutiny is appropriate." (citing Kornfeld v. Commissioner,
137 F.3d 1231, 1235 (10th Cir. 1998), afg T.C. Memo. 1996-472)). In doing so,
we ask what benefits an independent holder of the FSC stock could realistically
have expected on the basis of the "objective nature" of the FSC stock. Reddam…
IRCCourt RulingsMay 5, 1998
… 731 F.2d 1417,
1421 (9th Cir. 1984), affg. 79 T.C. 714 (1982); Markosian v.
Commissioner
, 73 T.C. 1235, 1245 (1980); Furman v. Commissioner
,
45 T.C. 360, 364 (1966), affd. per curiam 381 F.2d 22 (5th Cir.
1967). Petitioners presented no credible evidence that they
established Prindle for any reason other than tax av…
IRCCourt RulingsOct 4, 1979
…. 207, 209 (1969). In addition, section 707(b) has been used to elucidate the definition of section 1235(d) related persons when partnerships were involved. Burde v. Commissioner, 352 F.2d 995, 1000 (2d Cir. 1965). We find the greater than 50-percent interest test, when such interest is determined with reference to sec…
IRCCourt RulingsMar 30, 1978
…. 207, 209 (1969). In addition, section 707(b) has been used to elucidate the definition of section 1235(d) related persons when partnerships were involved. Burde v. Commissioner, 352 F.2d 995, 1000 (2d Cir. 1965). We find the greater than 50-percent interest test, when such interest is determined with reference to sec…
IRCCourt RulingsMar 31, 1981
…e than its usual substantial weight. Wisconsin Nipple & Fabricating Corp. v. Commissioner, 581 F.2d 1235 (7th Cir. 1978), affg. 67 T.C. 490 (1976); Commissioner v. Pepsi-Cola Niagara Bottling Corp., 399 F.2d 390 (2d Cir. 1968), revg. 48 T.C. 75 (1967), or that the taxpayer bears a heavy burden in attempting to overturn…
IRCCourt RulingsAug 15, 1994
…t the participant’s retirement. Vinson & Elkins v. Commissioner, 99 T.C. 9, 13 (1992), affd. 7 F.3d 1235 (5th Cir. 1993). The amount of the benefits each participant receives is usually determined by a formula described in the plan. The benefits provided by the-'plan are generally funded by annual contributions from an…
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 …
88 FR 60018 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements IRCProposed Rules (FR)Proposed Aug 30, 2023
…nal classifications from the DOL. This collection is approved by OMB under the DOL's Control Number 1235-0034. This IRS regulation does not alter any of the DOL collections approved under this control number.
The proposed regulations would include requirements to keep records
( printed page 60037)
IRCCourt RulingsJul 24, 2003related by meaning
1
Unless otherwise indicated, section references
hereafter are to the Internal Revenue Code in effect for the year
at issue.
T.C. Summary Opinion 2003-103
UNITED STATES TAX COURT
SANTOS M. AND INGRID I. CASTILLO, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4698-02S. Filed July 24, 2003.
Sant…
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…
IRCFinal Rules (FR)Oct 19, 2010
…IS 19374 (7th Cir. Sept. 15, 2003);
Lyons
v.
Georgia-Pacific Salaried Employees Ret. Plan,
221 F.3d 1235 (11th Cir. 2000),
cert. denied,
532 U.S. 967 (2001).
Notice 2007-6 (2007-1 CB 272),
see
§ 601.601(d)(2)(ii)(
75 FR 64197 — Additional Rules Regarding Hybrid Retirement Plans IRCProposed Rules (FR)Proposed Oct 19, 2010
…IS 19374 (7th Cir. Sept. 15, 2003);
Lyons
v.
Georgia-Pacific Salaried Employees Ret. Plan,
221 F.3d 1235 (11th Cir. 2000),
cert. denied,
532 U.S. 967 (2001).
Notice 2007-6 (2007-1 CB 272), see § 601.601(d)(2)(ii)(