IRCCourt RulingsFeb 9, 2023★ strong match
d. Reg. 17775), dated May 13,
1993 (58 Fed. Reg. 28446), dated May 18, 1993 (58 Fed.
Reg. 28921).” In our view, while the first correction related
214 to both the 1993 temporary regulation and the 1993 notice
of proposed rulemaking, the second and third corrections
related only to the 1993 temporary regulations. They d…
Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013related by meaning
ed do not apply to requests for any documents to the extent § 6104 applies.
Statement identifying information to be deleted from public inspection
.04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014related by meaning
f the adopted TAM to the taxpayer, or at the end of the 30-day period following the issuance of the TAM to the field.
Discussion with the taxpayer
.03 EP or EO Technical will not discuss the contents of the TAM with the taxpayer or the taxpayer’s representative until the taxpayer has been given a copy by the EP or EO E…
IRCCourt RulingsJul 14, 2005★ strong match
0 31
useaee
CAL,
Js.r. Juoca
T.C. Memo. 2005-173
UNITED STATES TAX COURT
TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket No. 1188-01. Filed July 14, 2005.
Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens,
for petitioner.
Jack Forsberg,…
IRCCourt RulingsMar 24, 2000
…ement accounts; and (3)
whether petitioner is liable for additions to tax under section 6651(a) for 1993 and 1994 or under section 6654(a) for 1993.
FINDINGS OF FACT
3
Petitioner resided at 318 Georgia Circle, Placentia,
California, during the tax years at issue and at the time her
petition was filed. Petitioner was bo…
IRCCourt RulingsJun 3, 1998related by meaning
…stituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a ruling
given to a specific taxpayer based upon the taxpayer's
specific facts and is not a ruling of general application.
See Golden Belt Tel. Association, Inc. v. Commissioner
, 108
T.C. 498, 506 (…
IRCCourt RulingsOct 3, 1995★ strong match
…e year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10066-93. Filed October 3, 1995.
Harold L. Humberson, pro se.
Alan R. Pere…
IRCCourt RulingsSep 28, 1998
r in the alternative, that the November 1993
distribution represented a cost-of-living adjustment.
Held
: P modified the series of substantially equal periodic payments by receiving the $6,776 from his IRA in
November 1993 prior to the close of the 5-ye ar period
beginning on the date of the first distribution in
Decem…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
07/01/1992
08/01/1992
6.25
08/01/1992
09/01/1992
6.00
09/01/1992
12/01/1992
5.75
12/01/1992
01/01/1993
6.00
01/01/1993
02/01/1993
5.75
02/01/1993
03/01/1993
5.50
03/01/1993
04/01/1993
5.25
04/01/1993
08/01/1993
5.00
08/01/1993
10/01/1993
4.75
10/01/1993
11/01/1993
4.25
11/01/1993
01/01/1994
4.25
01/01/1994
04/01/1994…
IRCCourt RulingsMar 6, 2001
services
not classified."
The second plan year for the TJM Pension Plan ended October
31, 1993. At trial, petitioner submitted the TJM Pension Plan's Annual Return of Fiduciary of Employee Benefit Trust (Schedule P,
Form 5500), the Return/Report of Employee Benefit Plan (Form
5500-C/R), the Actuarial Information (Sche…
ERISACourt RulingsAug 14, 2026
t this statement “necessarily implies that pre-1993 ret irees had lifetime, uncapped
benefits.” Kaiser, 2024 WL 1283535, at *4. But, read closely, this was not an affirmative statement or argument made by Alcoa;
it was simply a summary of the opposing side’s position. Such
statements cannot trigger judicial estoppel.
Seco…
IRCPrivate Letter RulingsMar 3, 2000related by meaning
…C:EBEO:4
TL-N-4712-99
UILC: 419.00-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR
FROM: Assistant Chief Counsel (Employee Benefits and Exempt
Organizations) CC: EBEO
SUBJECT:
This Field Service Advice is in res ponse to your memorandum dated October 5,
1999. Field Service Advice is not …
IRCCourt RulingsJul 31, 2000
…ion to Tax
Accuracy-Related Penalty
Year
Deficiency
Sec. 6651(a)(1)
Sec. 6662(a)
1992 $1,620 — $324
1993 6,262 — 1,252 John J. and Ophelia J. Mall, docket No. 1208-97
Addition to Tax
Accuracy-Related Penalty
Year
Deficiency
Sec. 6651(a)(1)
Sec. 6662(a)
1992 $6,186 — $1,237
1993 7,404 — 1,481
Lakewood Group
Lakewood, do…
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
addition, the notice invites comments from the public regarding all aspects of these provisions.
ADMINISTRATIVE
Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…
IRCPrivate Letter RulingsAug 27, 1999related by meaning
…Number: 199934002
Release Date: 8/27/1999
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Taxpayer's Name:
Taxpayer's Address:
Taxpayer's Ident. No.:
Taxable Years at Issue:
Date of Conference:
Legend
:
Taxpayer =
Plan =
Trust Agreement =
ISSUES
:
(1) Whether, under the rules of section 461 of the …
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsAug 6, 1997
…rs and did not obtain any evidence linking
petitioners to an income generating activity relating to 1993.
Nevertheless, respondent proceeded to use BLS data to reconstruct
petitioners' 1993 income. Therefore, respondent's determinations
relating to petitioners' 1993 tax years are arbitrary, and
respondent bears the bur…
IRCCourt RulingsJan 13, 2003
…Meyer gave birth to the couple’s only
child Richard J. Meyer IV (Richard).
Between February and May 1993, Mr. Meyer, Ms. Meyer, and
Richard moved to Seattle, Washington. In May 1993, Mr. Meyer and
Ms. Meyer separated. Mr. Meyer and Ms. Meyer did not enter into
a formal separation agreement.
After separating, Ms. Meyer …
T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. IRCTreasury DecisionsSep 18, 2006related by meaning
INCOME TAX
Notice 2006-76 Notice 2006-76
This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether i…
IRCCourt RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…