IRCCourt RulingsFeb 22, 1989related by meaning
the legislative intent, the rule of section 457(e)(1) does not apply and Foil’s 1981 employee contributions are not taxed until made available to him. Respondent maintains that section 252 of TEFRA removes “qualified State judicial plans” from the application of section 131 of R.A. 1978 but it does not provide any spec…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsJan 20, 1983related by meaning
nue Code of 1954 as amended and in effect during the year here in issue. All references to Rules are to the Tax Court Rules of Practice and Procedure. Absent special election, the "limitation year” is the calendar year. Sec. 1.415-2(b), Income Tax Regs. In this case, both the plan year and the limitation year were set …
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 …
IRCCourt RulingsFeb 9, 2023related by meaning
ory change was
discussed in the “Introduction” portion of the preamble to Treasury
Decision 8470. 58 Fed. Reg. 5264. Treasury Decision 8470 was issued the same day as the notice of proposed rulemaking , January 21, 1993,
setting forth the proposed regulations on foreign legal restrictions. T.D.
8470, 58 Fed. Reg. 5310;…
T.D. 9294 — Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recip… IRCTreasury DecisionsNov 27, 2006related by meaning
lans.
* * * * *
Par. 9. Section 1.7476-2 is amended by revising paragraph (c)(2) to read as follows:
§1.7476-2 Notice to interested parties.
* * * * * (c) * * *
(2) If the notice to interested parties is delivered using an electronic medium under an electronic system that satisfies the applicable notice requirements of…
IRCCourt RulingsJan 26, 1984related by meaning
shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
IRCCourt RulingsApr 22, 1992related by meaning
tatutoiy references are to the Internal Revenue Code in effect for 1986, and all Rule references are to the Tax Court Rules of Practice and Procedure. he parties have stipulated as follows:
8. During 1986, the petitioner, due to his termination of employment * * * received a total distribution from his employer's Incen…
IRCCourt RulingsJul 25, 1984related by meaning
cated, and all Rule references are to the Tax Court Rules of Practice and Procedure.
See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
IRCCourt RulingsApr 19, 1989related by meaning
e as amended and in effect for the year in issue unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. This subsection was repealed by the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2…
IRCCourt RulingsJul 24, 1991related by meaning
and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
tal wages. The regulations apply to all employers and others making supplemental wage payments to employees.
Announcement 2007-22 Announcement 2007-22 This document contains corrections to final regulations (T.D. 9263, 2006-25 I.R.B. 1063) relating to the deductions for income attributable to domestic production activi…
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 13, 1999related by meaning
penses which are ordinary
and necessary and recurring in nature. Respondent relies on Rev.
Rul. 86-142, 1986-2 C.B. 60, to support this position. This ruling, as discussed in detail below, concludes nonrecurring
expenses paid by an employer are not deductible under this
regulation. We disagree.
Our analysis starts at s…
T.D. 9219 — Final regulations under section 411(d)(6) of the Code provide guidance relating to the anti-cutback rules and the notification requirements under section 4980F. IRCTreasury DecisionsSep 19, 2005related by meaning
ion 204(h) amendment. Thus, for example, provisions relating to the right to make after-tax deferrals are not taken into account.
* * * * *
A-8. * * * (c) Application to certain amendments reducing early retirement benefits or retirement-type subsidies. Section 204(h) notice is not required for an amendment that reduce…
REG-138362-04 — Proposed regulations under section 401 of the Code provide guidance on the use of electronic media to provide certain notices to recipients or to transmit part… IRCProposed Rules (FR)Proposed Aug 15, 2005related by meaning
D FISCAL RESPONSIBILITY ACT OF 1982
Par. 8. The authority citation for part 35 continues to read, in part, as follows:
Authority: 26 U.S.C. 7805 * * * Par. 9. Section 35.3405-1 is amended by:
(1) Revising d-35, A.
(2) Removing d-36, Q&A.
The revision reads as follows:
§35.3405-1 Questions and answers relating to withho…
IRCCourt RulingsAug 8, 2005related by meaning
as provided in paragraphs (3)
and (4), paragraph (1) shall not apply to any of the
following distributions:
(A) In general.--Distributions which are-- (i) made on or after the date on which
the employee attains age 59 1/2,
(ii) made to a beneficiary (or to the
estate of the employee) on or after the death
(continued...…
T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o… IRCTreasury DecisionsMay 29, 2007related by meaning
2 Announcement 2007-52
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Rev. Proc. 2007-32 Rev. Proc. 2007-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers t…
IRCCourt RulingsSep 22, 1998related by meaning
ights-related activity. And
since none of petitioner's compensation for the year was
includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o).
Contributions are deemed to have been made to an IRA on the
last day of the preceding taxable year if the contribut…
IRCCourt RulingsMay 20, 1976related by meaning
tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty.
OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…