IRCCourt RulingsJul 24, 1991related by meaning
tever source derived, including (but not limited to) the following items: *******
(11) Pensions;
SEC. 451. GENERAL RULE FOR TAXABLE YEAR OF INCLUSION. (a) General Rule. — The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under th…
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…
IRCFinal Rules (FR)Dec 30, 2024
…st rate mode, the bond bears interest at a fixed interest rate, a qualified floating rate under § 1.1275-5(b), or an objective rate for a tax-exempt bond under § 1.1275-5(c)(5);
Notice 2013-84 — This notice contains the 2013 Cumulative List of Changes in Plan Qualification Requirements (2013 Cumulative List) described in section 4 of Rev. Proc. 2007–44… IRCNoticesDec 23, 2013
…mulative lists must be taken into account. These items can be found in Notice 2008–108, 2008–2 C.B. 1275.
1. 401(a):
IRCProposed Rules (FR)Proposed Dec 31, 2018
… bears interest during each interest rate mode at a fixed rate, a qualified floating rate under § 1.1275-5, or an objective rate that is permitted for a tax-exempt bond under § 1.1275-5(c)(5). Furthermore, interest on a qualified tender bond must be unconditionally payable at periodic intervals of no more than a year. …
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
Rev. Rul. 2012-5 — 2012 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2012 are provided for use in … IRCRevenue RulingsJan 30, 2012
INCOME TAX
T.D. 9561 T.D. 9561
Temporary and proposed regulations under section 1275 of the Code provide that a taxpayer must use the coupon bond method described in regulations section 1.1275-7(d) to account for Treasury Inflation-Protected Securities issued with more than a de minimis amount of premium. A public hear…
IRCCourt RulingsJan 9, 1985related by meaning
erest) on the dates shown was as follows:
Bate Balance
8/31/78 $123,727.08
8/31/79 131,211.18
8/31/80 141,708.07
8/31/81 144,502.33
4/ 9/84 131,432.30 Added to the Code by title II of the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. 93-406, sec. 2003, 88 Stat. 829, 971, section 4975 imposes two leve…
IRCCourt RulingsJun 17, 1997
…en for many taxpayers
who do not participate in these programs. * * *
[H. Rept. 98-432 (Part 2), at 1275-1276 (1984).]
As reflected in the report of the conference, the Congress
enacted subpart D with the understanding that subpart D's
principal purpose was “to prevent employers from taking premature
deductions, for ex…
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…
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…
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…
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. …
IRCCourt RulingsNov 30, 2006related by meaning
so. Despite the fact
that Mrs. Colombell received no tax benefit whatsoever from her
“participation” in Inova’s retirement plan, the Court is not free to rewrite the law. See, e.g., Hildebrand v. Commissioner
, 683
F.2d 57, 59 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Johnson v.
Commissioner
, 661 F.2d 53, 54-55 (5th …
PLR 201129029 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJul 22, 2011
…tax
under subchapter L in a transaction in which there is no consideration other than cash.
Section 1275(a)(1)(B)(ii).
8
Customer is considered the owner of the Account. Rev. Rul. 2003-92 , 2003-2 C.B. 350; Rev. Rul. 81 -
225, 1981-2 C.B. 12.
PLR - 143923-10 8
Section 1.165-1(d)(2)(i) provides that if a casualty or oth…
IRCCourt RulingsSep 25, 2019related by meaning
section 6651(a)(1) and (2), respectively.¹ Respondent has moved for
summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to
interrogatories, depositions, admissions, and any other acceptable materials,
together with the affidavits …
PLR 201128017 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJul 15, 2011
…tax under subchapter L in a transaction in which there is no consideration other than cash.
Section 1275(a)(1)(B)(ii).
8
Customer is considered the owner of the Account. Rev. Rul. 2003-92, 2003-2 C.B. 350; Rev. Rul. 81 -
225, 1981-2 C.B. 12.
PLR - 143921-10 8
life insurance product means a contract th at is treated for…
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…
PLR 201001016 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsJan 8, 2010
…tax
under subchapter L in a transaction in which there is no consideration other than cash.
Section 1275(a)(1)(B)(ii).
7
Taxpayer is considered the owner of the Account. Rev. Rul. 2003-92, 2003-2 C.B. 350; R ev. Rul. 81 -
225, 1981-2 C.B. 12.
8
PLR - 131336-08
In Boston Elevated Rwy v. Commissioner , 16 T.C. 1084, 1111…
PLR 200949007 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsDec 4, 2009
…ax
under subchapter L in a transaction in wh ich there is no consideration other than cash.
Section 1275(a)(1)(B)(ii).
4
Taxpayer is considered the owner of the Account. Rev. Rul. 2003-92, 2003-2 C.B. 350; Rev. Rul. 81 -
225, 1981-2 C.B. 12.
8
PLR - 112274-09
taxpayer purchased an insurance policy on his partner's life…