133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner IRCCourt RulingsSep 29, 2009
…graphs -(f) and (g) of this
section ." Petitioner -also 'cites Rev . Rul ; -66-266, 1966-2 . C .B .
356, and P .riv . Ltr- . Rul °'(PLR) 86-05-0,28 ; :"(Nov . : 4, 1985)10 for the
proposition that S ` corporation 'stock°held in -a -custodi"al account
for a disabled person or by a'custodian under the-Uniform Gift s
'°Pr…
IRCCourt RulingsJul 31, 2000
…
of that year, the conversion credit balance was $77,954.39
($34,317.46 + $51,470 - $11,189.96 + $3,356.89); the $3,356.89 is
the interest of 4.5 percent earned on the conversion credit
balance (($77,954.39 - $3,356.89) x 4.5% = $3,356.89)). Of the
conversion credit balance, $37,028.34 could have been transferred
at th…
IRCRegulationsJan 19, 2017
…ble with respect to stock acquired by a distribution or an exchange to which section 305, 354, 355, 356, or 1036 (or so much of section 1031 as relates to section 1036) applies. Stock so acquired shall, for purposes of sections 421 through 424, be considered as having been transferred to the individual upon his exercis…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
T.D. 9332 T.D. 9332 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…
IRCCourt RulingsMar 27, 1989related by meaning
tomatic retroactive disqualification for operational errors is a “Draconian approach” that is not sanctioned by either the statute or the regulations. Respondent argues, however, that section 415 places restrictions on employers’ deductions for contributions to employee plans because deferred compensation plans are sub…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
poses of this case, that the credit which petitioner will obtain is precisely equal to the amount of the creditable foreign taxes in terms of dollars. For the reasons stated, we hold that the foreign tax credit available to petitioner for fiscal 1967 should be adjusted to reflect the dollar cost on the payment date of …
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
… and they often do not fully understand their self-insured group health plans' contracts with PBMs.[356]
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…
IRCCourt RulingsFeb 9, 2023★ strong match
le &
Co. v. Commissioner , 88 T.C. at 356. Section 240(f) of the Re venue Act
of 1926 was part of the consolidated-return provisions of the Act. These provisions were in section 240 of the Act, 44 Stat. at 46. Section 240(a)
of the Revenue Act of 1926, 44 Stat. at 46, permitted affiliated
corporations to file consolida…
91 FR 33900 — Federal Independent Dispute Resolution Operations IRCFinal Rules (FR)Jun 4, 2026
…burden associated with the proposed changes would be 65,100 hours with an equivalent cost of $2,575,356.[277]
This would result in a cost associated with this policy of $503,773 ($2,575,356−$2,071,583).[278]
86 FR 55980 — Requirements Related to Surprise Billing; Part II IRCFinal Rules (FR)Oct 7, 2021
ests between 2022-2024 to be $356,727,765 (inclusive of printing, materials, mailing costs) and total burden hours of 3,538,305, as shown in Table 44. HHS estimates the annual cost for printing and materials to provide written good faith estimates to uninsured (or self-pay) individuals to be $314,905. The mailing costs…
IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
IRCCourt RulingsAug 3, 1979related by meaning
Chabot, Judge:
Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows:
Deficiencies in—
Docket No. Petitioners Income tax gi
6173-77 John L. Guest .$437.60
9115-77 James Ventresca and Jordy L. Ventresca . 296.00
Jerome Kobos . 286.18
Edward And…
IRCCourt RulingsMar 13, 1974
…tt_ 2, 527. 99 1, 685. 32
Chester M. Davis__ 2, 527. 99 1, 685. 33
George B. LaLonde_ 2, 034. 72 1, 356. 48
Max C. Jordan_ 2, 034 72 1, 356. 48
E. L. Snyder_ 2, 034 72 1, 356. 48
W. S. Walters_ 168. 16 112. 10
Ronnie G. Smith_ 115. 84 463. 38
Jim D. Humphrey_ 74 74 112. 10
Louise G. Winerich_ 44 84 29. 90
James H. Clay…
88 FR 37186 — Malta Personal Retirement Scheme Listed Transaction IRCProposed Rules (FR)Proposed Jun 7, 2023related by meaning
tax-favored under the same country's laws) must be made in cash and must be based on income earned from employment or self-employment activities.
See sections 219, 408, and 408A. Third, in appropriate fact patterns, the transaction viewed as a whole may be disregarded under relevant judicial doctrines, including the s…
IRCCourt RulingsFeb 24, 2011
…the Schedule A, petitioner claimed deductions ;for, inter
- 4 -
alia, home mortgage interest of $54,356 and medical expenses of
$27,008.3
Relying on various Forms 1099 from third-party payors,
including petitioner's husband's former employer, respondent
determined in the notice of deficiency that petitioner failed to
r…
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…
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…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968
…treated as reported return of advance capital receipt
1960. $99,061.60 $96,673.63 $367,497.72
1961. 356,621.77 348,025.07 863,932.46
1962. 356,621.77 348,025.07 (318,611.88
The facilities exclusively service Pease Air Force Base and had been in continuous use by the Government under the contractual arrangements with pe…
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…