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83 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 89 FR 54284 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCFinal Rules (FR)Jun 28, 2024
    …an five percent of the partnership's gross income, including tax-exempt income described in section 705(a)(1)(B), in the case of income or gain items, or gross expenses and losses, including section 705(a)(2)(B) expenditures, in the case of losses and expense items; and the total amount of the extraordinary items from …
  2. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013related by meaning
    Mr. Villasenor was injured on or about May 13, 2000. Although the file is much more extensive than that of Ms. Muriel and it appears that petitioners hired and paid attorneys through 20 3 to handle the appeal of the worker's compensation claim, Ms. Strick's name does not appear on any of the documents, and she did not…
  3. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    Cumulative Difference -0-4,184,771 1,856,154 3,504,159 680,612 CD OO <Ji 1,025,021 5,209,792 1,705,633 5,209,792 -0-CD OO <3 Total 5,209,792 5,209,792 Petitioner’s payment to the National Presto VEBA during the 1986 taxable year in the amount of $1,856,154 relates solely to amounts that petitioner had previously deduct…
  4. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024★ strong match
    …edure . 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 accuracy-related penalties under section 6662(a) . Respondent has since conceded th e section 6651(a)( 2 ) additions to tax and the …
  5. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    … Memo. 1970-304. A partner's adjusted basis in his partnership interest is determined under section 705. A partner's initial basis in a partners hip is determined by the amount of money contributed and the adjusted basis of any other type of property contri buted. Sec. 722. The partner's basis in the partnership is the…
  6. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023
    …work for adjusting a partner's basis in its partnership interest based on the principles of section 705 when a partner recognizes section 987 gain or loss, defers section 987 gain or loss, or suspends section 987 loss attributable to a partnership. See
  7. 89 FR 100138 — Taxable Income or Loss and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCFinal Rules (FR)Dec 11, 2024
    principles of section 705 as though the section 987 gain or loss was part of the partner's distributive share of partnership items. See § 1.987-7(e). A commenter requested clarification concerning the interaction of this basis adjustment rule with section 704(d). Section 704(d)(1) provides that a partner's distributiv…
  8. 88 FR 80910 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCProposed Rules (FR)Proposed Nov 20, 2023
    …an five percent of the partnership's gross income, including tax-exempt income described in section 705(a)(1)(B), in the case of income or gain items, or gross expenses and losses, including section 705(a)(2)(B) expenditures, in the case of losses and expense items; and the total amount of the extraordinary items from …
  9. 84 FR 65464 — Transparency in Coverage
    IRCProposed Rules (FR)Proposed Nov 27, 2019
    …ents Number of responses Burden hours per respondent Total burden hours Total cost 1,959 23,508 360 705,240 $70,567,725 The Departments estimate the total one-time hour burden for all health insurance issuers and TPAs of 2,331,210 hours and an associated equivalent cost of approximately $211,386,679 to develop and buil…
  10. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  11. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022★ strong match
    …tices of deficiency determining , for tax years 2004– 2014, excise tax deficiencies totaling $8,476,705 1 Unless otherwise indicated, all statutory references are to the Internal Revenue Code (Code), Title 26 U.S.C., in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Pro…
  12. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007★ strong match
    …ubmitted a self-prepared statement, incorporated in his brief, detailing when and how he spent $123,705 of the pension distribution on Starlight Productions . 5 Respondent argues, citing section 402(a) and 402(e)(1)(A), that petitioner must include in his 2002 income the $168,355 .71 pension distribution . Regarding th…
  13. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010
    …aressof their- respectiv e companies . See sec . 1367(a)(1) (for .the S corporations) secs . ; 702, 705 (for JELMAC, LLC, a partnership) ; Briggs'v . Commissioner , T .C . Memo . 2000-380 ("Generally, a shareholder's adjusted basis in S corporation stock is increased for his or her share of the pass-through amounts-") …
  14. 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…
  15. 82 FR 56545 — 18-Month Extension of Transition Period and Delay of Applicability Dates; Best Interest Contract Exemption (PTE 2016-01); Class Exemption for Principal Transac…
    ERISAFinal Rules (FR)Nov 29, 2017
    …ity to delay the PTE conditions and amendments as proposed. They focused their arguments on section 705 of the APA (5 U.S.C. 705), which permits an agency to postpone the effective date of an action, pending judicial review, if the agency finds that justice so requires. These commenters say that this provision is the o…
  16. T.C. Memo. 2010-263 — Ernestine Forrest v. Commissioner
    IRCCourt RulingsDec 2, 2010related by meaning
    wers v. Commissioner, 24 T.C. 199, 239 (1955), affd. 247 F.2d 233 (2d Cir. 1957), affd. sub nom. Bonney v. Commissioner, 247 F.2d 237 (2d Cir. 1957)); see also sec. 1 165-1(d) (2) (i), Income Tax Regs. This is especially true in a case involving insurance. Section 165(a) prohibits a taxpayer from deducting any amount c…
  17. 138 T.C. No. 20 — Shannon L. Fernandez v. Commissioner
    IRCCourt RulingsMay 14, 2012related by meaning
    4(a)(1) exclude541 from Mr. Fernandez' income the amounts he received from - 6 - LACERA. The question is whether the same section excludes the amounts petitioner received attributable to Mr. Fernandez' benefits under the stipulated division of retirement benefits. . Petitioner argues that the $11,691 is excluded from h…
  18. 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. …
  19. PBGC Op. Ltr. 2002-1 — Termination, Restoration
    PBGCPBGC Opinion LettersDec 10, 2002
    …he funding schedule for restored pe nsion plans, subject to important restrictions. 55 Fed. Reg. 42,705 (Oct. 23, 1990). This reg ulation (codified at 26 C.F.R. § 1.412(c)(1)-3) cre ates 3 Restoration creates unique problems with respect to plan funding . The plan's funding standard account is closed out at the time of…
  20. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022related by meaning
    . See FPL Grp., Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994).…