T.D. 9142 — REG-101447-04 Final regulations under section 408(q) of the Code provide requirements relating to deemed IRAs that may be included in qualified employer plans,… IRCTreasury DecisionsAug 23, 2004
*
§1.408(q)-1 also issued under 26 U.S.C. 408(q). * * *
Par. 2. In §1.408-2, paragraph (e)(5)(v)(A) is revised and (e)(8) is added to read as follows: §1.408-2 Individual retirement accounts
* * * * *
(e) * * *
(5) * * *
(v) Custody of investments. (A) Except for investments pooled in a common investment fund in accord…
Notice 2023-27 — The notice announces that the Treasury Department and the IRS intend to issue guidance related to the treatment of certain nonfungible tokens (NFTs) as section… IRCNoticesApr 10, 2023
… Department and the IRS intend to issue guidance regarding the treatment of certain NFTs as section 408(m) collectibles. Pending the issuance of that guidance, the IRS intends to determine whether an NFT constitutes a section 408(m) collectible by analyzing whether the NFT’s associated right or asset is a section 408(m…
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 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…
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…
IRCCourt RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …
IRCCourt RulingsJul 8, 1980related by meaning
2,300.
All statutory references are to the Internal Revenue Code of 1954 as in effect during the year in issue.
Sec. 6652(c) states in pertinent part: (c) Failure To Report Tips. — In the case of failure by an employee to report to his employer on the date and in the manner prescribed therefor any amount of tips requir…
IRCCourt RulingsNov 25, 2008related by meaning
…propriate relief available to the
individual under this section * * *
- 6 - 109-432, div . C, sec . 408(a), 120 Stat . 3061 (TRHCA sec . 408) .4
This amendment applies "with respect to liability for taxes
arising or remaining unpaid on or after the date of the enactment
of this Act ." Id . sec . 408(c), 120 Stat . 3062…
IRCCourt RulingsAug 30, 1993related by meaning
inciples, and such a transfer will subject the employer to the excise tax on employer reversions." H. Rept. 100-391, at 143 (1987) (emphasis added). 4 *66 We recognize that Notice 88-58, supra, was released after the year in issue. It is clear, however, from the face of the statute as well as from the legislative histo…
IRCPrivate Letter RulingsMay 27, 2016
termined without regard to section 408(d)(3)).
Section 408(d)(3)(8)
of the Code provides that section 408(d)(3) does not apply to any
amount described in section 408(d)(3)(A)(i) received by an individual from an IRA if at
any time during the 1-year period ending on the day of such receipt such individual
received any o…
IRCCourt RulingsDec 2, 1981related by meaning
n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case.
An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
IRCPrivate Letter RulingsSep 30, 2016
gross income (determined without regard to section 408(d)(3)).
Section 408(d)(3)(B)
of the Code provides that section 408(d)(3) does not apply to any amount described in section 408(d)(3)(A)(i) received by an individual from an IRA if at
any time during the 1-year period ending on the day of such receipt such individu…
IRCPrivate Letter RulingsDec 11, 2015
…on of the amount received which is
includible in gross income (determined without regard to section 408(d)(3}). Section 408(d)(3)(B) of the Code provides that section 408(d)(3) does not apply to any
amount described in section 408(d)(3)(A)(i) received by an individual from an
IRA if at
any time during the 1-year period…
IRCPrivate Letter RulingsOct 16, 2015
includible
in gross income (determined without regard to section 408(d)(3)).
Section 408(d)(3)(B) of the Code provides that section 408(d)(3) does not apply to any amount described in section 408(d)(3)(A)(i) received by an individual
from an IRA if at any time during the 1-year period ending on the day of such
receipt …
IRCCourt RulingsMar 9, 2011related by meaning
ities. Classification of the
transaction as a prohibited transaction under section
408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is
subject to a 10-percent additional tax. See secs. 72(t),
408(e) (2) (]B). In cases where the Service att…
IRCPrivate Letter RulingsSep 18, 2015
…on of the amount received which is
includible in gross income (determined without regard to section 408(d)(3)).
Section 408(d)(3)(B) of the Code provides that section 408(d)(3) does not apply to any
amount described
in section 408(d)(3)(A)(i) received by an individual from an IRA if at
any time during the 1-year period…
IRCCourt RulingsMay 30, 1984related by meaning
was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
IRCCourt RulingsNov 26, 1985★ strong match
…1280, at 339, 1974-3 C.B. 415, 500.[] The foregoing excerpt from the legislative history of section 408(c)(3) makes it clear that petitioner’s borrowing from John Hancock against his annuity contract was precisely the type of transaction which Congress sought to discourage by means of that statutory provision.
IRCPrivate Letter RulingsSep 2, 2016
…on of the amount
received which is
includible in gross income (determined without regard to
section 408(d)(3)).
Section 408(d)(3)(B) of the Code provides that section 408(d)(3) does
not
apply to any
amount described
in section 408(d)(3)(A)(i) received by an
individual from an IRA if at any time during the 1-year period…
IRCPrivate Letter RulingsJul 8, 2016
…on of the
amount received which is includible
in gross income (determined without
regard to section 408(d)(3)).
Section 408(d)(3)(8) of the Code provides that section 408(d)(3) does not apply
to any amount described
in section 408(d)(3)(A)(i) received by an individual from
an
IRA if at any time during the 1-year period…