IRCCourt RulingsMar 7, 2019
…es that BAI placed these assets in service before its
2003 tax year--the year BAI claimed a section 179 deduction for them. BAI's own
records say the "Equipment--Krom." and the "Equipment--Henn." were placed in
service after the start of its 2003 tax year. But BAI admitted on brief that "[t]he
evidence shows that these…
IRCProposed Rules (FR)Proposed May 13, 2026
…ulgated, have a significant economic impact on a substantial number of small entities, section 603 [179]
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
…the selection of annuity providers under 29 CFR 2550.404a-4).
Cf. McNeil
v.
Time Ins. Co.,
205 F.3d 179, 190 (5th Cir. 2000) (“ERISA's section 505 granted the Secretary of Labor the authority to promulgate regulations for implementation of ERISA, and the Secretary has created an exemption for certain group or group-typ…
IRCCourt RulingsSep 14, 1993
3,179.00 does not qualify for the 10-year averaging method because you do not meet the requirements of section 402 of the Internal Revenue Code. * * * (b) It is determined that your tax on an IRA is $1,317.90 ($13,179.00 times 10 percent) in lieu of $1,377.90 as shown in your return.[]
(c) It is determined that you are…
IRCCourt RulingsNov 3, 2008
…s actually rendered" .-
tion 79 Expens e
deduct as a current expense the
imitations, of any section 179
d
8 -
property that is used in an active trade or business and placed
in service during the taxable year . Sec . 179(a), (b), (d)(1) ;
see sec . 1 .179-4(a), Income Tax : Regs . ,The election must specifythe total se…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
itioner and his wife
owned 100 percent of the Garrahan Agency, and since petitioner is
a disqualified person under section 4975(e)(2)(A), the Garrahan Agency is a disqualified person under section 4975(e)(2)(G).
3. Conclusion
The Garrahan Agency is a disqualified person under section
4975(e)(2), and thus it and petitio…
IRCCourt RulingsJun 9, 1965
…h were to be sold and transferred to the petitioner, had a book value as of May 31, 1957, of $1,576,179.57. In accordance with the above-mentioned agreement of May 22, that the buyers were to pay $300,000 less than the book value of said assets, the total purchase price to be paid by Fohrman and Dorgan or their nominee…
IRCCourt RulingsJul 30, 1985related by meaning
the instant case, as the excess of the amount contributed to the IRA for the taxable year over the amount allowable as a deduction under section 219. Since petitioner is not entitled to a deduction under section 219 for his contribution for $1,500 to an IRA in 1981, the entire $1,500 represents an excess contribution …
IRCCourt RulingsMar 5, 1987related by meaning
ies thereby created.
We likewise hold that sec. 220(b)(3)(A)(iv) is not applicable to disallow petitioners’ claimed IRA deductions. See note 16 supra. Since there is a complete absence in the legislative history of sec. 219 as to whether art. Ill judges were to be allowed the benefits of IRA contributions, we cannot sp…
IRCCourt RulingsFeb 18, 1997related by meaning
l section references are
to the Internal Revenue Code in effect for 1991, the taxable year
in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
2
Sec. 4980A imposes a 15-percent excise tax on excess
distributions from qualified retirement plans. This tax is
included within ch. 43 of the I…
Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par… IRCRevenue ProceduresModified Aug 2, 2021
…uture enhancements
178
PART II. PROGRAM EFFECT AND ELIGIBILITY
SECTION 3. EFFECT OF EPCRS; RELIANCE
179
.01 Effect of EPCRS on retirement plans
179
.02 Compliance statement
179
.03 Excise and other taxes
179
.04 Reliance
179
SECTION 4. PROGRAM ELIGIBILITY
179
.01 EPCRS Programs
179
.02 Effect of examination
180
.03 SCP…
Rev. Proc. 2020-4 — This revenue procedure contains information on the types of advice provided by the Commissioner, Tax Exempt and Government Entities Division, Employee Plans Ru… IRCRevenue ProceduresJan 2, 2020
…tions under § 414(h)
178 .07 Other limits on scope of determination letter
178
.08 Leased employees
179
.09 Partial terminations
179
.10 Publication 794, Favorable Determination Letter
179
SECTION 10. WHAT IS THE GENERAL PROCEDURE FOR REQUESTING DETERMINATION LETTERS?
179
.01 Scope
179
.02 Complete information required…
IRCCourt RulingsJan 14, 2013
…31 19,545 10,562 -0- 10,562
1993 41,365 20,800 20,565 10,132 -0- 10,132
1992 39,908 20,800 19,108 9,179 -0- 9,179
1991 38,502 -0- 38,502 9,323 .-0- 9,323
IRCCourt RulingsApr 16, 2020
…125,952 ---
Utilities 5,239 5,239 5,239 ---
Office expenses 3,060 3,060 3,060 ---
Depreciation/sec. 179 expense 36,179 36,179 --- 36,179
Car and truck expenses 756 756 --- 756
Advertising 435 435 435 ---
Repairs and maintenance 71 71 71 ---
i. Wages
On brief respondent concedes that petitioners have substantiated BJWre…
IRCCourt RulingsSep 30, 1991related by meaning
o the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. This is the figure that appeared on the front page of both notices of deficiency. The computations attached to the notices both used the figure $81,023.94 for the additi…
IRCCourt RulingsNov 25, 1996
…nt allowed
petitioner an additional withholding credit of $25 representing
taxes withheld on the $1,179 unreported wage income.
early distributions from qualified retirement plans under section
72(t).
The issues for decision are: (1) Whether petitioner failed
to report wage income of $1,179 in 1992; (2) whether petitio…
Rev. Proc. 2017-4 — This procedure contains consolidated and revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government … IRCRevenue ProceduresJan 3, 2017
…an
178
.03 Timing of determination letter applications for adopting employers of pre-approved plans
179
SECTION 14.WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR INDIVIDUALLY DESIGNED MULTIPLE EMPLOYER PLANS?
179
.01 Scope
179
.02 Controlling member must accompany any multiple employer plan submission
179
.03 …
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
nal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.
VI. DRAFTING INFORMATION The principal authors of this notice are Naomi Lehr, Vernon Carter, and Pamela R. Kinard of the Office of Associate Chief Counsel (Employee Benefits, Exempt Organization…
IRCCourt RulingsJul 25, 1974related by meaning
ew principal place of work.
Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217.
SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
IRCCourt RulingsNov 5, 1999
…0
3
for the Defined Benefit Plan reports total plan assets as of the
beginning of the plan year of $179,296 and $191,680 at the end of
the plan year. In addition, the Form 5500 reports $129,031 as
"any loan or extension of credit by the plan to the employer, any
fiduciary, any of the five most highly paid employees of …