IRCCourt RulingsJun 18, 1999★ strong match
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsJan 17, 2024related by meaning
…n and not as findings of fact in this case. See
Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994). Petitioner resided in Washington when he petitioned this Court. Absent stipulation to the contrary, appeal of this
case would apparently lie to the U.S. Court of Appeals for th…
91 FR 16088 — Fiduciary Duties in Selecting Designated Investment Alternatives ERISAProposed Rules (FR)Proposed Mar 31, 2026
… two surveys' findings as a basis, the Department assumes the meeting frequency factors in Table 6.[199]
91 FR 4348 — Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure ERISAProposed Rules (FR)Proposed Jan 30, 2026
…than doubled from 2011 to 2013, indicating a substantial increase after the final rule took effect.[199]
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
…ed guidance
198
.05 Issues in prior return
198
.06 Generally not to business associations or groups
199
.07 Generally not to foreign governments
199
.08 Generally not on federal tax consequences of proposed legislation
199
SECTION 25. UNDER WHAT CIRCUMSTANCES DOES EMPLOYEE PLANS RULINGS AND AGREEMENTS HAVE THE DISCRETI…
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…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024
…1-1(a)(1) and (2) as to who is the owner of a qualified film or television production. (42) Section 199.—Income Attributable to Domestic Production Activities.—The determination under § 1.199-3(f)(1) as to who is the taxpayer that has the benefits and burdens of ownership under Federal income tax principles of any qual…
IRCCourt RulingsAug 6, 1991related by meaning
…e are not presented with a sec. 72(t) issue. See Shimota v. United States, 21 Cl. Ct. 510, 525-526 (1990), on appeal (Fed. Cir., Nov. 1, 1990).
The Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat. 1388, while maintaining this option for a severely limited class of eligible individuals, suspended it…
IRCCourt RulingsJul 5, 1983related by meaning
the taxable year in issue. Since petitioner was an active participant in a qualified plan during that year, we must uphold respondent’s determination. Inasmuch as petitioner’s IRA contribution was properly, disallowed, the imposition of the 6-percent excise tax under section 4973(a) must be sustained with respect to pe…
Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Dec 30, 2024
…e a copy of plan and amendments
198
.04 Restatements required
198
.05 Section 414(x) combined plans
199
SECTION 12. WHEN MAY AN ADOPTER OF A PRE-APPROVED PLAN (STANDARDIZED OR NONSTANDARDIZED) SUBMIT A DETERMINATION LETTER APPLICATION?
199
.01 Eligibility to apply for a determination letter for a Cycle 3 qualified pre-…
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. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t… IRCRevenue ProceduresSuperseded Jan 4, 2021
…03 Determination letter applications on Form 5300
196
.04 Scope of review
198
.05 Submission period
199
.06 Reliance equivalent to determination letter
199
SECTION 13. WHAT ARE THE DETERMINATION LETTER FILING PROCEDURES FOR FORM 5307?
199
.01 Scope
199
.02 Form 5307 filing procedures
199
.03 Additional information with…
IRCCourt RulingsFeb 25, 2016
…er Strategies is entitled to business expense deductions for meals
and entertainment expenses of $2,199 and $4,739 for 2004 and 2005, respectively,
and travel expenses of $53,707 for 2005;
(4) whether petitioner is liable for additions to tax under section 6651(a)(1)
for failure to file Forms 5329, Additional Taxes on …
Rev. Proc. 2018-4 — This procedure contains revised procedures for determination letters and letter rulings issued by the Commissioner, Tax Exempt and Government Entities Division… IRCRevenue ProceduresJan 2, 2018
…f subsequent publication of revenue ruling, etc.
198
.04 Effect of subsequent amendment by employer
199
.05 Revocation or modification of a determination letter
199
.06 Determination letter revoked or modified based on material change in facts applied retroactively
199
.07 Not otherwise generally revoked or modified re…
IRCCourt RulingsDec 23, 1996related by meaning
…uishable from the present one.
In view of the foregoing, we hold that petitioner is not
taxable, in 1990, on the net wages withheld by the school
district during that year. Because 1990 is the only year before
us, we need not, and do not, decide whether the net wages are
taxable in some other year.
Issue (2): Section 7…
75 FR 19542 — Benefits Payable in Terminated Single-Employer Plans; Interest Assumptions for Valuing and Paying Benefits PBGCFinal Rules (FR)Apr 15, 2010
…)
On or after Before
i1
i2
i3
n1
n2
* * * * * * *
199
5-1-10
6-1-10
3.00
4.00
4.00
4.00
7
8
3. In appendix C to part 4022, Rate Set 199, as set forth below, is added to the table.
APPENDIX C TO PART 4022—LUMP SUM INTEREST RATES FOR PRIVATE-SECTOR PAYMENTS
* * * * *
( pr…
IRCCourt RulingsNov 10, 1998related by meaning
…er is liable for the 10-percent
additional tax on premature distributions from a qualified plan
for 1992 as provided in section 72(t).
To reflect the above,
Decision will be entered
under Rule 155
.
Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Jan 3, 2023
…hority must be distinguished
198
.10 Employer-employee relationship
198
.11 Incomplete applications
199
.12 Effect of failure to disclose material fact
199
.13 Where to file requests
199
.14 Submission of related plans
200
.15 Withdrawal of requests
200
.16 Right to status conference
200
.17 How to request status confe…
IRCCourt RulingsAug 12, 1980related by meaning
.
Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable years in issue. SEC. 4973. TAX ON EXCESS CONTRIBUTIONS TO INDIVIDUAL RETIREMENT ACCOUNTS, CERTAIN SECTION 403(b) CONTRACTS, CERTAIN INDIVIDUAL RETIREMENT ANNUITIES, AND CERTAIN RETIREME…