§2004

Estate of Steve K. Backemeyer, Deceased, Julie K. Backemeyer, Personal Representative, and Julie K. Backemeyer, Petitioners · 2016

2004(a), 129 Stat. at 454. It is hardly unforeseeable that taxpayers would attempt to deduct previously expensed inherited assets for which they received a stepped-up basis, yet at no point has - 31 - Congress acted to prevent it. Indeed, the Court ofAppeals for the First Circuit has observed that the intent ofsection 1014 is "that unrealized

Estate of Joseph L. Mangiardi, Deceased; Joseph L. Mangiardi Declaration of Trust Dated February 13, 1998, Maureen G. Mangiardi, Co-Trustee and Statutory Executor, Petitioners T.C. Memo. 2011-24 · 2011

n agency of the gover ment must scrupulously observe rules, regulations or procedures which it has established. When it fails, to do so, its action cannot stand 2While Congress amended sec. 6161(a) (2) in the Tax Reform Act of 1976, Pub. L. 94--455, sec. 2004(c), 90 Stat. 1867, to substitute the words "reasonable cause" for "undue hardship", the regulations havè never been updated to refléct this chanse: Nevertheless, we refer to them here because the legislative history indicates clearly that r

Alfred E. & Lynn B. Holland, Petitioner · 2000

ary stock to its shareholders, within the 5-year period, does violate the requirements of sec. 355(b)(2)(D). The prior distribution to P also violates sec. 355(b)(2)(D) as amended by the Revenue Act of 1987, sec. 10223(b), 101 Stat. 1330, supra, and sec. 2004(h)(1) of TAMRA, supra. As a result, Rev. Rul. 89-37, 1989 C.B. 107, obsoletes the holding of Rev. Rul. 74-5, supra, with respect to the distribution to P.

Douglas P. McLaulin, Jr., Petitioner · 2000

ary stock to its shareholders, within the 5-year period, does violate the requirements of sec. 355(b)(2)(D). The prior distribution to P also violates sec. 355(b)(2)(D) as amended by the Revenue Act of 1987, sec. 10223(b), 101 Stat. 1330, supra, and sec. 2004(h)(1) of TAMRA, supra. As a result, Rev. Rul. 89-37, 1989 C.B. 107, obsoletes the holding of Rev. Rul. 74-5, supra, with respect to the distribution to P.

Augustus H. King, III, Petitioner · 2000

ary stock to its shareholders, within the 5-year period, does violate the requirements of sec. 355(b)(2)(D). The prior distribution to P also violates sec. 355(b)(2)(D) as amended by the Revenue Act of 1987, sec. 10223(b), 101 Stat. 1330, supra, and sec. 2004(h)(1) of TAMRA, supra. As a result, Rev. Rul. 89-37, 1989 C.B. 107, obsoletes the holding of Rev. Rul. 74-5, supra, with respect to the distribution to P.

William R. Norwalk, Petitioner T.C. Memo. 1998-279 · 1998

Code section 2004 (West 1990) provides the proper method of distributing corporate assets in a dissolution: - 30 - After determining that all the known debts and liabilities of a corporation in the process of winding up have been paid or adequately provided for, the board shall distribute all the remaining corporate assets among the shareholders accord

Lear Eye Clinic, Ltd., An Arizona Professional Corporation, Petitioner 106 T.C. No. 23 · 1996

Section 415 was added to the Internal Revenue Code by section 2004(a)(2) of the Employee Retirement Income Security Act of 1974 (ERISA), Pub.

Lear Eye Clinic, Ltd., Petitioner 106 T.C. No. 23 · 1996

Section 415 was added to the Internal Revenue Code by section 2004(a)(2) of the Employee Retirement Income Security Act of 1974 (ERISA), Pub.

Peaje Investments LLC v. PR Highways and Transportation · Cir.

Peaje Invs. LLC v. Fin. Oversight & Mgmt. Bd. for P.R. (In re Fin. Oversight & Mgmt. Bd. for P.R.) 899 F.3d 1 · Cir.

Lear Eye Clinic, Ltd. v. Commissioner 106 T.C. 418 · 1996

Estate of Papson v. Commissioner 73 T.C. 290 · 1979

United States v. Jack Jepsen · Cir.

Assured Guaranty Corp. v. Commonwealth of Puerto Rico · Cir.

United States of America v. Jack Jepsen Kris Jepsen Karen Jepsen Makutenas 268 F.3d 582 · Cir.

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