§3307 — Deductions as constructive payments
5 citing cases
Statute Text — 26 U.S.C. §3307
Whenever under this chapter or any act of Congress, or under the law of any State, an employer is required or permitted to deduct any amount from the remuneration of an employee and to pay the amount deducted to the United States, a State, or any political subdivision thereof, then for purposes of this chapter the amount so deducted shall be considered to have been paid to the employee at the time of such deduction.
Treasury Regulations
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Treas. Reg. §31.3307-1Deductions by an employer from remuneration of an employee
Any amount deducted by an employer from the remuneration of an employee is considered to be a part of the employee's remuneration and is considered to be paid to the employee as remuneration at the time that the deduction is made. It is immaterial that any act of Congress or the law of any State requires or permits such deductions and the payment of the amount thereof to the United States, a State, or any political subdivision thereof.
5 Citing Cases
"The "taxpayer" referred to in sec.
in person" alternative means ofnotification is just that, an alternative to notification by mail to the taxpayer's last known address, which was added in 1998 by the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105-206, sec. 3307, 112 Stat. at 744. Therefore, the statute permits the Commissionerto choose which method to use and does not require the Commissioner to ensure the taxpayer's actual receipt ofthe notice. See Mason v. Commissioner, 132 T.C. 301, 322-323 (20
section 3307.63(A) and (B) (Anderson 2002) provides that STRS disability retirement payments comprise both an annuity and a pension. STRS calculated the amount excludable from petitioners’ gross income under section 72(b) to be $995.40 in each of the years 1999 and 2000. The notice of deficiency accepts this computation. B. Section 105 Petitioners