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 …
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…
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…
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 …
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…
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
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…
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 …
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…
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…
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…
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…
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-") …
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…
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…
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…
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…
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. …
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…
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).…