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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   t ions on allocations of income under section 482 of the Internal Revenue Code of 1954. The 1969 revision to the Code of Federal Regulations contained regulations promulgated on or before December 31, 1968. See 26 (p art 1 (secs. 1.401-1.500)) C.F.R. v ( 1969). Included in the 1969 revision was section 1.482-1, which c…
2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   number of TLC's customers applied the sec. 274(n)(1) limitation to any amounts that they paid to TLC. "Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be entitled to the remedy it seeks. If, as petitioner asserts, certain trucking company clients applied the s…
3. 78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans
   IRCFinal Rules (FR)Dec 26, 2013
   …  Bureau: § 1026.42(b)(1) and (2); Board § 226.42(b)(1) and (2). Back to Citation 145.   See HUD TI-481, Appendix 2-1, D (General Program Requirements—Eligible Homes). Back to Citation 146.  When the home is classified as real property, the appraisal must be completed by a real estate appraiser on the FHA Title II rost…
4. 78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
   IRCFinal Rules (FR)Sep 19, 2013
   …. However, other commenters asserted that any change in method of accounting must include a section 481(a) adjustment. The final regulations provide that, except as otherwise stated, a change to comply with the final regulations is a change in method of accounting to which the provisions of sections 446 and 481 and the…
5. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003related by meaning
   foregoing statutory - 19 - requirements were satisfied for the audit year. Therefore, we reject petitioner’s claim, raised at trial, to deductions for three dependency exemptions. VI. Respondent’s Section 72(t) Determination Section 72(t) provides, in pertinent part, as follows: SEC. 72(t). 10-Percent Additional Tax on…
6. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
   IRCCourt RulingsOct 9, 1997related by meaning
   einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
7. PLR 200641008 — Governmental Plan
   IRCPrivate Letter RulingsOct 13, 2006
   …ontract. In Rev. Rul. 75-302 , 1975-2 C.B. 86, Rev. Rul. 75-303, 1975-2 C.B. 87, and Rev. Rul. 76 - 481, 1976-2 C.B. 82, taxpayers were allowed a current deduction of payments for future medical care extendi ng substantially beyond the close of the taxable year in situations where the future care was purchased in conne…
8. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
   IRCCourt RulingsFeb 18, 1997
   …itioners disclosed the receipt of distributions from petitioner's IRA's in the total amount of $181,481. Of this amount, petitioners reported $8,762 as the taxable amount. The Notice of Deficiency
9. T.C. Memo. 2007-306 — David Brian Nolan v. Commissioner
   IRCCourt RulingsOct 9, 2007
   …e term "eligible educational institution " means an institution-- (A) which is described in section 481 of the Higher Education Act of 1965 (20 U .S .C . 1088), as in effect on the date of the enactment of this paragraph, an d (B) which is eligible to participate in a program under Title IV of such Act . -7Paragraph (5…
10. 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…
11. I.R.C. § 404A(g)(5) — Deduction for certain foreign deferred compensation plans
    IRCCode / StatuteJan 14, 2019
    (g)(5) (5) Section 481 applies to election For purposes of section 481, any election under this section shall be treated as a change in the taxpayer's method of accounting. In applying section 481 with respect to any such election, the period for taking into account any increase or decrease in accumulated profits, earn…
12. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
13. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
14. 74 T.C. 651 — Judd v. Commissioner
    IRCCourt RulingsJul 8, 1980related by meaning
    minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
15. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
16. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991
    …payments — prior to the receipt thereof by the participant or beneficiary. Petitioner reported $107,481.39 of the $182,481.39 lump-sum distribution on Form 4972 (Special 10-Year Averaging Method) included with his 1983 tax return. The difference between the amount reported and the amount received under the Sears plan i…
17. 86 FR 55980 — Requirements Related to Surprise Billing; Part II
    IRCFinal Rules (FR)Oct 7, 2021
    …ioners to develop, prepare, print, post the notices, and make website updates will be approximately 481,426 total burden hours. This results in an equivalent cost of approximately $75,075,712.[276] HHS assumes that each individual physician practitioner will incur a printing cost of $0.05 per page and materials for a t…
18. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004
    …For example, an involuntary change generally is made with an earlier year of change and a shorter § 481(a) adjustment period for a positive adjustment, and a voluntary change generally is made with a current year of change and a longer § 481(a) adjustment period of a positive adjustment. See generally Rev. Proc. 97-27,…
19. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019
    …inment expenses (after reducing the amount by the 50% limitation imposed by section 274(n)), and $9,481 for business expenses other than passenger automobile expenses, parking fees, tolls, transportation, travel expenses, and meal
20. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986★ strong match
    … of Linderme v. Commissioner, 52 T.C. 305 (1969); Estate of Garner v. Commissioner, T.C. Memo. 1982-481, 44 T.C.M. 903, 51 P-H Memo T.C. par. 82,481; Estate of Stubblefield v. Commissioner, T.C. Memo 1981-353, 42 T.C.M. 343, 50 P-H Memo T.C. par. 81,353. And in connection with the position that even a reserved life est…