29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…
PLR 202031008 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJul 31, 2020
… and other evidence of managerial
power was lacking).
Non - Grantor Trust
PLR - 137676-17
6
Section 641(a) generally provides that the tax imposed by section 1(e) applies to
the taxable income of estates or of any kind of p roperty held in trust. Section 1.641(a) –
0(b) provides that subparts A through D of part I of s…
IRCCourt RulingsFeb 9, 2023★ strong match
Decision 5426 does not appear to be relevant to the dispute in L.E.
S hunk Latex . Indeed, because the regulatory amendments of Treasury Decision 5426 merely mirrored changes made to the relevant statute, it would appear that even a
dispute implicating the text of the regulatory amendments of Treasury Decision 5426
wou…
IRCCourt RulingsJul 14, 2005related by meaning
ld a second trial at which
petitioner would introduce new evidence in support of that
position.
With respect to petitioner's tax duplication argument, petitioner asserts:
As a result of the Court's Opinion in this case
and without a Rule 155 proceeding, respondent will be
in a windfall position-it will have collected t…
PLR 202118002 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsMay 7, 2021
…ridden by settlor and other evidence of managerial
power was lacking).
Non - Grantor T rust Section 641(a) generally provides that the tax imposed by section 1(e) applies to
the taxable income of estates or of any kind of property held in trust. Section 1.641(a) –
0(b) provides that subparts A through D of part I of su…
IRCFinal Rules (FR)Jul 19, 2024
…butions from the definition of an eligible rollover distribution. Prior to being amended by section 641 of EGTRRA, section 402(c)(8)(B) of the Code provided that the only type of eligible retirement plan permitted to receive a rollover from a qualified plan was another qualified plan or an IRA. Section 641 of EGTRRA am…
IRCProposed Rules (FR)Proposed Feb 24, 2022
…butions from the definition of an eligible rollover distribution. Prior to being amended by section 641 of EGTRRA, section 402(c)(8)(B) of the Code provided that the only type of eligible retirement plan permitted to receive a rollover from a qualified plan was another qualified plan or an IRA. Section 641 of EGTRRA am…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
…r J
Ordinarily, t he income tax treatment of trusts and their
beneficiaries is governed by sections 641 through 66 8 . Generally, trusts
are taxed as separate entities . § 641(b). Trusts may deduct amounts
distributed or required to be distributed to a beneficiary. §§ 651, 661.
8
On brief respondent raises three altern…
IRCCourt RulingsNov 14, 1996★ strong match
ear that were
listed in the letter of credit, in the amount of $2,092,421. By
way of a net operating loss carryback, petitioner also claimed a
- 5 -
3 [T]he words of such an act as the Income Tax * * *
merely dance before my eyes in a meaningless
procession: cross-reference to cross-reference,
exception upon exception …
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 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…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976related by meaning
ed plans. The amounts so allowable may be determined in computing the decision in accordance with Rule 155, Tax Court Rules of Practice and Procedure. Decision will be entered under Rule 155.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the years in issue.
(b) Retroactivity of R…
IRCCourt RulingsJan 29, 2019related by meaning
ents was this estimate, to which respondent reserved an objection on
grounds of relevance and authenticity. We overrule respondent's objection.
- 38 - noncorporate taxpayers to deduct losses on the sale or exchange of capital assets
to the extent of the gain from such sales or exchanges, plus the lower of:
(1) $3,000 o…
PLR 202445015 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsNov 8, 2024
…oner ,
306 F.2d 682, 687 (1st Cir. 1962), aff’g Archibishop Samuel Trust v. Comm issioner , 36
T.C. 641 (1961), acq. , 1964-2 C.B. 3:
Inherent in the concept of an annuity is a transfer of cash or property from
IRCCourt RulingsDec 19, 1995
…rt, may raise the estoppel on its own motion
in an appropriate case." In re Cassidy
, 892 F.2d 637, 641 (7th
Cir. 1990) (fn. ref. omitted) (citing Allen v. Zurich Ins. Co.
,
667 F.2d 1162, 1168 n.5 (4th Cir. 1982)). The United States
Court of Appeals for the Fifth Circuit acknowledged the right of
appellate courts to r…
IRCCourt RulingsMar 15, 2011
…rowth and Tax Relief Reconciliation Act of 2001 ,
EGTRRA was enacted on June 7, 2001." EGTRRA secs.
641(a) (1) (A) and (b) (2), 115 Stat. 118, 120, required qualifiedplans to amend their definition of an eligible retirement plan to
include eligible deferred compensation plans under section 457(b)
and annuity contracts …
IRCCourt RulingsJun 29, 1956related by meaning
OPINION.
TuRNee, Judge:
By section 403 (c) (6) of the Eenegotiation Act of 1943, the profits received under a subcontract, as defined by section 403 (a) (5) (B) of the Act, are not subject to renegotiation, unless the aggregate of the amounts received or accrued in a fiscal year ending after June 30,1943, exceeds $25,0…
78 FR 72018 — Allocation of Assets in Single-Employer Plans; Valuation of Benefits and Assets; Expected Retirement Age PBGCFinal Rules (FR)Dec 2, 2013
…ly benefit at URA is greater than—
From—
To—
2015
614
614
2,594
2,594
2016
627
627
2,651
2,651
2017
641
641
2,710
2,710
2018
655
655
2,769
2,769
2019
670
670
2,830
2,830
2020
685
685
2,893
2,893
2021
700
700
2,956
2,956
2022
715
715
3,021
3,021
2023
731
731
3,088
3,088
2024 or later
747
747
3,156
3,156
1
Table II-A.
2
…
IRCCourt RulingsFeb 6, 1992related by meaning
and the temporary regulations rather than the general deduction-timing rules (i.e., normal rules of accrual accounting) of the Internal Revenue Code. In summary, we hold that section 1.404(b)-lT, Temporary Income Tax Regs., is a valid temporary regulation, that petitioner has not brought itself within any exception th…