Internal Revenue Code

“ Primarily we have to consider § 122 of the Internal Revenue Code, which, to a limited degree, permits reflection of the fact that income in one year may, in the not uncommon fluctuation of business affairs, have been offset by losses incurred in subsequent or preceding years. ”

“ Adjustment.—The amount of the maximum current policy adjustment shall be the difference between— (A) total revenues projected to be collected and outlays to be paid under the Internal Revenue Code of 1986 (as scheduled on December 31, 2009, to be in effect) ; and (B) what those revenue collections and outlay payments would have been if, on the date of enactment of legislation meeting the criteria in paragraph (1) , the provisions identified in paragraph (1) were made permanent. ”

“ REPEAL OF REGULATIONS. The final regulations of the Department of the Treasury relating to guidance under section 6033 of the Internal Revenue Code of 1986 regarding the reporting requirements of exempt organizations (published at 85 Fed. Reg. 31959 (May 28, 2020) ) shall have no force and effect. ”

“ The Federal tax system should be simple, fair, efficient, and pro-growth. The purposes of tax regulations should be to bring clarity to the already complex Internal Revenue Code (title 26, United States Code) and to provide useful guidance to taxpayers. ”

“ Treas.Reg. 111, § 29.23 (m) -1; and Treas.Reg. 118, § 39.23 (m) -1 (a) - (b) , with Treas.Reg. § 1.611 1 (b) (1) . This Regulation has survived through successive amendments of the Internal Revenue Code and therefore is entitled to great weight. ”

“ For taxpayers who do owe the payment, its amount is determined by such familiar factors as taxable income, number of dependents, and joint filing status. §§ 5000A (b) (3) , (c) (2) , (c) (4) . The requirement to pay is found in the Internal Revenue Code and enforced by the IRS, which—as we previously explained—
[p564] must assess and collect it "in the same manner as taxes." Supra, at 545–546. This process yields the essential feature of any tax: It produces at least some revenue for the Government. United States v. ”

“ In the 1939 Internal Revenue Code that section was part of Subchapter B, 'Determination of Tax Liability,' which was a part of chapter 34, 'Information and Returns,' which in turn was part of Subtitle D, 'GENERAL ADMINISTRATIVE PROVISIONS.' SECTIOn 61 mADe applicable tO the income tax provisions 'All administrative special, or stamp provisions of law, including the law relating to the assessment of taxes, so far as applicable * * *.' These administrative provisions include the chapter and subtitle of which § 3616 (a) is a part. ”

“ The United States is seeking recovery of this money in a suit now pending in the United States District Court for the Northern District of California, Southern Division. The amount at issue there is something over $500,000.↑ Pertinent sections of the Internal Revenue Code of 1939 provide: § 23. ”

“ Pfennig, 541 U.S. 232, 242 (2004) (quoting United States v. Mead Corp., 533 U.S. 218, 227 (2001) ) . In this case, however, the parties disagree over the proper framework for evaluating an ambiguous provision of the Internal Revenue Code. ”

“ The arm of the taxgatherer reaches far. In my judgment it should not go the length of this case. Congress has revised § 23 once to overcome niggardly construction. [13] It should not have to do so again.
Notes
↑ 26 U.S.C. § 23 (a) (1) (A) , as amended, 56 Stat. 819, 26 U.S.C.A. Int.Rev.Code, § 23 (a) (1) (A) .↑ No claim for deduction was made by the taxpayer for the amounts spent in traveling from Mobile to Jackson. He also took trips during the taxable years to Washington, New York, New Orleans, Baton Rouge, Memphis and Jackson (Tenn.) ”

“ The incorporation of the regulation in section 113 (a) (5) of the 1928 Act was intended to clarify, but not to change, the law. See Report of House Committee on Ways and Means, No. 2, 70th Cong., 1st Sess., p. 18; Report of Senate Committee on Finance, No. 960, 70th Cong., 1st Sess., p. 26; Report of Joint Committee on Internal Revenue Taxation, H.R. Doc. ”

“ We agree that these decisions held invalid a regulation like Art. 23 (m) -10 (c) which includes in income for a taxable year deductions allowed in prior years. The effect of the Commissioner's acquiescence is uncertain. Cf. C.B. XIII-2-IV. During the period of acquiescence, the regulation continued in existence and was republished n the edition of December 1, 1931, approved February 15, 1929, of Regulations 74 under the Revenue Act of 1928, Art. ”