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61 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    4131/1962 and Provisional Measure No. 2224, dated September 4, 2001, if the licensee made an unauthorized remittance by either (a) making payments to a foreign person (controlling or noncontrol ling) without prior recordation of an agreement required to be recorded at the BPTO, or (b) making payments to a foreign cont…
  2. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    ion. See 1994 U.S./French Tax Convention art. 23(4), 2 Tax Treaties (CCH) par. 2001.24. Article 18 of the 1994 U.S./French Tax Convention, rather than Article 19 in the now-superseded convention signed in 1967, - 11 - governs deductions for pension payments made in 2001. The French Foreign Ministry publication does not…
  3. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024
    ….C. 714, 719 – 20 (1982), aff’d , 731 F.2d 1417 (9th Cir. 1984); Markosian v. Commissioner, 73 T.C. 1235, 1244 – 45 (1980); Saccato v. Commissioner, T.C. Memo. 2023-96, at *8. Whether a trust
  4. PLR 201432029 — Excise Tax on Certain Accumulations in Qualified Retirement Plans
    IRCPrivate Letter RulingsAug 8, 2014related by meaning
    arding enforceable claims of the parties; and (ii) the parties' assessments of the relative strengths of their positions. We further conclude that the final settlement agreement approved by Court Order is within the range of reasonable outcomes under the governing instruments and applicable State law. Therefore, based …
  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. 167 T.C. No. 4 — Piton Holdings, LLC, David L. Hall, Partnership Representative, Petitioner(s) v. Commissioner
    IRCCourt RulingsJul 15, 2026
    …iry begins and ends with the statute ’ s plain language. ” Shockley v. Commissioner, 686 F.3d 1228, 1235 (11th Cir. 2012), rev’g and remanding T.C. Memo. 2011-96. Section 6662 is not ambiguous with respect to the issue in dispute. The statutory text is clear that the adequate disclosure exception does not apply to the …
  7. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …ily the decisions by this Court in Vinson & Elkins v. Commissioner, 99 T.C. 9 (1992), aff'd, 7 F.3d 1235 (5th Cir. 1993), and Citrus Valley Estates, Inc. v. Commissioner, 99 T.C. 379 (1992), aff'd in part, remanded in part, 49 F.3d 1410 (9th Cir. 1995), for putative support for its position on actuarial equivalence. Fo…
  8. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    …e related, so heightened scrutiny is appropriate." (citing Kornfeld v. Commissioner, 137 F.3d 1231, 1235 (10th Cir. 1998), afg T.C. Memo. 1996-472)). In doing so, we ask what benefits an independent holder of the FSC stock could realistically have expected on the basis of the "objective nature" of the FSC stock. Reddam…
  9. T.C. Memo. 1998-164 — Roland R. & Virginia A. Fox v. Commissioner
    IRCCourt RulingsMay 5, 1998
    … 731 F.2d 1417, 1421 (9th Cir. 1984), affg. 79 T.C. 714 (1982); Markosian v. Commissioner , 73 T.C. 1235, 1245 (1980); Furman v. Commissioner , 45 T.C. 360, 364 (1966), affd. per curiam 381 F.2d 22 (5th Cir. 1967). Petitioners presented no credible evidence that they established Prindle for any reason other than tax av…
  10. T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409…
    IRCTreasury DecisionsJan 18, 2005related by meaning
    INCOME TAX Rev. Rul. 2005-3 Rev. Rul. 2005-3 Section 901(j)(5) Presidential waiver; Libya. Pursuant to a section 901(j)(5) Presidential waiver, section 901(j)(1) of the Code ceased to apply to Libya effective December 10, 2004. Section 911(d)(8) is not applicable to Libya after September 20, 2004, and Iraq after July 2…
  11. IRCCourt RulingsOct 4, 1979
    …. 207, 209 (1969). In addition, section 707(b) has been used to elucidate the definition of section 1235(d) related persons when partnerships were involved. Burde v. Commissioner, 352 F.2d 995, 1000 (2d Cir. 1965). We find the greater than 50-percent interest test, when such interest is determined with reference to sec…
  12. IRCCourt RulingsMar 30, 1978
    …. 207, 209 (1969). In addition, section 707(b) has been used to elucidate the definition of section 1235(d) related persons when partnerships were involved. Burde v. Commissioner, 352 F.2d 995, 1000 (2d Cir. 1965). We find the greater than 50-percent interest test, when such interest is determined with reference to sec…
  13. 76 T.C. 499; 2 Employee Benefits Cas. (BNA) 1145 — Fujinon Optical, Inc. v. Commissioner
    IRCCourt RulingsMar 31, 1981
    …e than its usual substantial weight. Wisconsin Nipple & Fabricating Corp. v. Commissioner, 581 F.2d 1235 (7th Cir. 1978), affg. 67 T.C. 490 (1976); Commissioner v. Pepsi-Cola Niagara Bottling Corp., 399 F.2d 390 (2d Cir. 1968), revg. 48 T.C. 75 (1967), or that the taxpayer bears a heavy burden in attempting to overturn…
  14. 103 T.C. 200; 103 T.C. No. 13 — Rubin v. Commissioner
    IRCCourt RulingsAug 15, 1994
    …t the participant’s retirement. Vinson & Elkins v. Commissioner, 99 T.C. 9, 13 (1992), affd. 7 F.3d 1235 (5th Cir. 1993). The amount of the benefits each participant receives is usually determined by a formula described in the plan. The benefits provided by the-'plan are generally funded by annual contributions from an…
  15. Rev. Rul. 2007-67 — Mortality tables; single sum distributions; section 417(e)(3) of the Code. This ruling pertains to the mortality table to be used when calculating a single sum…
    IRCRevenue RulingsNov 26, 2007related by meaning
    INCOME TAX T.D. 9362 T.D. 9362 Temporary and proposed regulations under section 905 of the Code provide rules relating to a United States taxpayer's obligation to notify the Internal Revenue Service of a foreign tax redetermination, which is a change in foreign tax liability that may affect the taxpayer's foreign tax c…
  16. 88 FR 60018 — Increased Credit or Deduction Amounts for Satisfying Certain Prevailing Wage and Registered Apprenticeship Requirements
    IRCProposed Rules (FR)Proposed Aug 30, 2023
    …nal classifications from the DOL. This collection is approved by OMB under the DOL's Control Number 1235-0034. This IRS regulation does not alter any of the DOL collections approved under this control number. The proposed regulations would include requirements to keep records ( printed page 60037)
  17. T.C. Summary Opinion 2003-41 — Larry Joe Mills v. Commissioner
    IRCCourt RulingsApr 22, 2003related by meaning
    to section 72(t)(2)(C) for relief. It does not appear that any of the statutory exceptions to the application of section 72(t) apply in this case, and petitioner has not suggested otherwise. - 7 - The Court concurs in respondent's determination that petitioner is subject to the 10-percent additional tax on an early dis…
  18. Treas. Reg. § 54.4975-14(a) — Election to pay an excise tax for certain pre-1975 prohibited transactions.
    IRCRegulationsDec 30, 2016related by meaning
    (a) (a) In general. Section 2003(c)(1)(B) of the Employee Retirement Income Security Act of 1974 (88 Stat. 978) provides an election to pay an excise tax by certain persons involved prior to 1975 in prohibited transactions within the meaning of section 503 (b) or (g).
  19. 75 FR 64123 — Hybrid Retirement Plans
    IRCFinal Rules (FR)Oct 19, 2010
    …IS 19374 (7th Cir. Sept. 15, 2003); Lyons v. Georgia-Pacific Salaried Employees Ret. Plan, 221 F.3d 1235 (11th Cir. 2000), cert. denied, 532 U.S. 967 (2001). Notice 2007-6 (2007-1 CB 272), see § 601.601(d)(2)(ii)(
  20. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983related by meaning
    so determined that petitioners were liable for an addition to tax under sec. 6651(a) in the amount of $28.76. Respondent conceded that issue on brief. The procedures set forth in sec. 7463 apply to cases involving taxes imposed by subtitle A and Chs. 11 and 12 of the Code, subject to monetary limits. As to petitions fi…