IRCCourt RulingsDec 11, 2003related by meaning
f section 6501,
1
section 6651(a)(1),
2
- 37 -
2
(...continued)
(2003) ; Janpol v. Commissioner
, 102 T.C. 499, 503, 505 (1994);
Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, aff…
IRCCourt RulingsFeb 9, 2023★ strong match
…n ˚ 9413- 59.
(Official Gazette, May 29, 1959).
The English translation of Exhibit 30 - J (Portaria 314/70) is:
Ordinance/MF n˚ 314/70. Includes the 2nd Group --
p rocessing industry
Eng. MF 314/70 --Port. --Ordinance FINANCE MINISTER
OF --MF n ˚ 314 of 25.11.1970
D.O.U.: 12/01/1970
(Includes the 2nd Group --Manufactur…
IRCCourt RulingsJan 20, 1983related by meaning
e, and we must therefore uphold its validity.
III. Petitioner’s Miscellaneous Contentions
1. Effective Date of Section 1.415-5(c)(l), Income Tax Regs. Section 1.415-1(f), Income Tax Regs., states that section 1.415-5(c)(l), Income Tax Regs., is effective for plan years beginning after 1975 and that, for all such plan y…
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…
IRCCourt RulingsJan 12, 1998related by meaning
the deduction would frustrate a sharply defined
Federal or State policy. Wood v. United States
, 863 F.2d 417
(5th Cir. 1989); Fuller v. Commissioner , 213 F.2d 102 (10th Cir.
1954), affg. 20 T.C. 308 (1953); Holmes Enterprises v.
Commissioner
, 69 T.C. 114 (1977). The test of nondeductibility
is the severity and imme…
IRCCourt RulingsJan 30, 2007
…otice of deficiency. Respondent determined a deficiency in petitioners'
2000 Federal income tax of $314,372, based on respondent's
determination that petitioners were liable for alternative
minimum tax of $314,371.6 Respondent also determined that
s It is unclear·how petitioners calculated the tax on IRAs
and other ret…
IRCCourt RulingsFeb 22, 1989related by meaning
n from sec. 457 altogether.
We note the irony that, on answering brief in another issue in the instant case, petitioners make the following statement: It is improper to resort to legislative history where the statute is clear. U.S. v. Prudential Ins. Co. of America, 461 F.2d 280 (5th Cir. 1972); U.S. v. Marett, 325 F.2…
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…utual fund underwriters
Rule Review:
Total
$70,714,175
$3,061,442
$866,069
$66,284
Per-Entity
826
3,314
3,314
3,314 Disclosure:
Total
64,897,138
65,955
Per-Entity
758
249
Policies and Procedures:
Total
1,025,087
Per-Entity
3,923
Retrospective Review:
Total
32,571,012
Per-Entity
124,640
Self-Correction:
Total
201,363
Pe…
IRCCourt RulingsFeb 24, 2014
…in section
415(c)(3)(D) was effective for taxable years beginning after December 31, 1997.
CRA sec. 314(g), 114 Stat. at 2763A-643 ("The amendments made by this section
shall take effect as if included in the provisions of the Taxpayer Relief Act of 1997
to which they relate."); Taxpayer Relief Act of 1997 (TRA 97), Pu…
T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner IRCCourt RulingsApr 27, 1998
on 314(c)(1) of the
Economic Recovery Tax Act of 1981 (ERTA), Pub. L. 97-34, 95 Stat.
172, 286, provides that a distributee is taxed on benefits under a qualified retirement plan in the tax year in which those
benefits are "actually distributed". Prior to the 1981
amendment, section 402(a)(1) provided that amounts held…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsSep 29, 1992★ strong match
…the mortality and interest components. The table used by Lawrence for 1985 used an interest rate of 314 percent and mortality data from 1949.
Respondent argued that the use of the Manulife table was unreasonable because it used a 314-percent interest rate, and it was programmed into Lawrence’s computer, so no individua…
IRCCourt RulingsJun 10, 1996related by meaning
mount necessary to fund the
benefits payable under section 415 determined at the time of the
contribution in question. Citrus Valley Estates, Inc. v
. Commissioner
, 99 T.C. at 447. The dispute in these cases focuses
on the amounts of benefits payable under section 415 determined
at the time of the contributions in que…
81 FR 19086 — Amendments to the Definition of Broker or Dealer in Securities IRCProposed Rules (FR)Proposed Apr 4, 2016
…undering and terrorist activity requirements.[40]
Sections 1010.520 and 1010.540 implement sections 314(a) and 314(b) of the USA PATRIOT Act, respectively.
Under the section 314(a) requirements, brokers or dealers in securities must respond to requests for information made by FinCEN on behalf of Federal, state, and loc…
IRCCourt RulingsDec 19, 1989
…consisted of $30,199.69 nontaxable return of his own contribution to “regular savings account” and $314,306.28 taxable distribution comprising “employer profit sharing contribution and increase thereof, super savings, and increase of employee contribution to regular saving account.” Although petitioners had other items…
84 FR 62449 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Paying Benefits PBGCFinal Rules (FR)Nov 15, 2019
…)
On or after Before
i1
i2
i3
n1
n2
* * * * * * *
314
12-1-19
1-1-20
0.25
4.00
4.00
4.00
7
8
3. In appendix C to part 4022, rate set 314 is added at the end of the table to read as follows:
Appendix C to Part 4022—Lump Sum Interest Rates for Private-Sector Payments
* * …
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
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…
Rev. Rul. 2024-1 — This revenue ruling provides tables of covered compensation under § 401(l)(5)(E) of the Internal Revenue Code and the Income Tax Regulations thereunder, effect… IRCRevenue RulingsJan 8, 2024
…arity in employer-provided contributions or benefits
EMPLOYEE PLANS, EXCISE TAX
Notice 2024-1, page 314.
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…