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95 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 86 FR 36872 — Requirements Related to Surprise Billing; Part I
    IRCFinal Rules (FR)Jul 13, 2021
    …each with an equivalent cost of $7,354,578. The 3-year average cost burden for DOL and Treasury is $279,389 each. The summary of burden below encompasses the following ICRs: (1) Information to be Shared about the QPA (26 CFR 54.9816-6T(d), 29 CFR 2590.716-6(d)), (2) Complaints Process for Surprise Medical Bills (26 CFR…
  2. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    individual.5 See H. Rept. 378, 87th Cong., 1st Sess. 89 (1961), 1962-3 C.B. 261, 279-280. A Petitioner concludes that on the 'basis of the legislative history a common law employee who has self -employment earnings is treated as an owner-employee and is entitled to make retirement plan contributions and deduct those co…
  3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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…
  4. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    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…
  5. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  6. Treas. Reg. § 1.421-1(j)(2) — Meaning and use of certain terms.
    IRCRegulationsSep 9, 2016
    …y options granted on or before June 9, 2003, taxpayers may rely on the 1984 proposed regulations LR-279-81 (49 FR 4504), the 2003 proposed regulations REG-122917-02 (68 FR 34344), or this section until the earlier of January 1, 2006, or the first regularly scheduled stockholders meeting of the granting corporation occu…
  7. 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…
  8. Treas. Reg. § 1.421-2(f) — General rules.
    IRCRegulationsJan 19, 2017
    …y options granted on or before June 9, 2003, taxpayers may rely on the 1984 proposed regulations LR-279-81 (49 FR 4504), the 2003 proposed regulations REG-122917-02 (68 FR 34344), or this section until the earlier of January 1, 2006, or the first regularly scheduled stockholders meeting of the granting corporation occu…
  9. 35 T.C. 1217 — Searl v. Commissioner
    IRCCourt RulingsMar 31, 1961related by meaning
    ntract” as meaning the entire contract, especially since Congress, when it wished to delineate the annuity feature of the contract, did so explicitly. Although admitting that the interpretation proposed by petitioner is not without merit, we hold that section 72(d) applies only when the entire consideration furnished b…
  10. 72 T.C. 461 — Citrus Orthopedic Medical Group, Inc. v. Commissioner
    IRCCourt RulingsJun 11, 1979related by meaning
    n 61 and Section 83 routes, nor need we decide whether Section 83 applies only to stock plans. Cf. Sakol v. Commissioner, 67 T.C. 986, 989-991 (1977). We think it is plain that the transfers to the trust in the instant case, if they were completed ones, were additional compensation to McElwee and Smith and the amounts …
  11. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    … on Sept ember 6, 1934.”); Thomas E. Jenks, “Treasury Regulations Under Section 482”, 23 Tax Lawyer 279, 279 (1970) (“The * * * regulations were issued in 1934” . ). 77 (5) “ Group” or “group of controlled taxpayers ” means the organizations, trades, or businesses owned or controlled by the same interests. (6) The term…
  12. Treas. Reg. § 1.422-5(f)(2) — Permissible provisions.
    IRCRegulationsSep 9, 2016
    …y options granted on or before June 9, 2003, taxpayers may rely on the 1984 proposed regulations LR-279-81 (49 FR 4504), the 2003 proposed regulations REG-122917-02 (68 FR 34344), or this section until the earlier of January 1, 2006, or the first regularly scheduled stockholders meeting of the granting corporation occu…
  13. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  14. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
  15. Treas. Reg. § 1.424-1(g)(2) — Definitions and special rules applicable to statutory options.
    IRCRegulationsJan 19, 2017
    …y options granted on or before June 9, 2003, taxpayers may rely on the 1984 proposed regulations LR-279-81 (49 FR 4504), the 2003 proposed regulations REG-122917-02 (68 FR 34344), or this section until the earlier of January 1, 2006, or the first regularly scheduled stockholders meeting of the granting corporation occu…
  16. 87 FR 45204 — Proposed Amendment to Prohibited Transaction Class Exemption 84-14 (the QPAM Exemption)
    ERISAProposed Rules (FR)Proposed Jul 27, 2022
    …stimates that the cost burden for preparing and mailing the notices will be approximately equal to $279, that is, 410 * ((2 * $0.05) + $0.58) = $279 (rounded). Therefore, the total cost associated with this requirement is (8* legal professional labor rate of $140.96) + (13.7* clerical labor rate $55.23) + $279 = $2,180…
  17. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    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…
  18. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  19. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …issioner, T.C. Memo. 2008-262, 96 T.C.M. (CCH) 354, 357 ; cf . Old Colony Tr . Co. v. Commissioner, 279 U.S. 716, 729 (1929) (“ [D]ischarge by a third person of an obligation to [the taxpayer] is equivalent to receipt by the person taxed.”). More specifically, IRA funds constitute gross income as an involuntary distrib…
  20. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    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…