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Go to T.C. Memo. 2001-198 (not yet in the library — opens the official source)
90 documents · 0.46sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    … and June 30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M. (CCH) 1707 (a case involving tax years 1979, 1980, and 1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d 825 (5th Cir. 1996) In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
  2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    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,…
  3. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010
    …its sole member . Ms . O'Boyle received nonemployee compensation from Red Barn Actors studio during 2001 and 2002 . Neither petitioner was employed by any third party during 2000, 2001, or 2002 . Petitioners did not file a timely .tax return for the 2000, 2001, or 2002 tax years . Mr . O'Boyle paid $10,000 toward his p…
  4. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
  5. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005
    ion. See 1994 U.S./French Tax Convention art. 23(4), 2 Tax Treaties (CCH) par. 2001.24. Article 18 of the 1994 U.S./French Tax Convention, rather than Article 19 in the now-superseded convention signed in 1967, - 11 - governs deductions for pension payments made in 2001. The French Foreign Ministry publication does not…
  6. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    …d by the language of the statute as it is written”); Badaracco v. Commissioner , 464 U.S. 386, 398 (1984) (“Courts are not authorized to rewrite a statute because they might deem its effect susceptible of improvement.”). The Tax Court is a court of limited jurisdiction and lacks general equitable powers. Commissioner v…
  7. Rev. Proc. 2004-25 — Remedial amendment period; disqualifying provisions; December 31, 2001. This procedure extends the remedial amendment period under section 401(b) of the Code w…
    IRCRevenue ProceduresApr 19, 2004
    …] SECTION 3. EXTENSION OF REMEDIAL AMENDMENT PERIOD FOR DISQUALIFYING PROVISIONS AFTER DECEMBER 31, 2001 .01 The remedial amendment period with respect to disqualifying provisions described in § 1.401(b)-1(b)(1) that are put into effect (in the case of new plans) or adopted (in the case of existing plans) after Decembe…
  8. T.C. Summary Opinion 2005-126 — Carolyn A. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    …king account where she deposited her paychecks. During the period from July 27 through December 31, 2001, Mr. Glenn wrote checks totaling $66,082.07 drawn on the Harris Trust & Savings Bank joint checking account as follows: - 6 - Date Check No. Description Amount 7/27/2001 136 Payable to: Discover $2,700.00 8/1/2001 1…
  9. Notice 2004-34 — Minimum funding standards; interest rates; section 101 of Pension Funding Equity Act. This notice describes the method for determining the permissible range of…
    IRCNoticesMay 3, 2004
    …14 (not a toll-free number). Table 1 Composite Corporate Bond Rates Composite Rates for: Month 2000 2001 2002 2003 2004 January 7.94 7.34 6.92 6.07 5.68 February 7.84 7.21 6.86 5.90 5.63 March 7.87 7.08 7.10 5.89 5.44 April 7.84 7.28 7.03 5.91 May 8.27 7.28 6.99 5.42 June 8.05 7.17 6.76 5.24 July 7.93 7.13 6.74 5.77 Au…
  10. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    …U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984)). Accordingly, in order to give effect to our disposition of the disputed issue, as well as respondent's concession, and to permit - 16 - 12 See supra notes 5, 7. the parties to address the minor unexplained discre…
  11. T.C. Memo. 2006-101 — Eugenie Denise Mitchell v. Commissioner
    IRCCourt RulingsMay 11, 2006
    …counts were made with funds which were not included in petitioner's taxable income. On February 28, 2001, petitioner's then-current employer went out of business, and petitioner was laid off. As a result of being laid off, in the spring of 2001 petitioner applied for and received unemployment benefits from the State of…
  12. T.C. Memo. 2011-2 — Michael C. Hollen, D.D.S., P.C. v. Commissioner
    IRCCourt RulingsJan 4, 2011
    … Amendment Effective Adopted . Effective Section Date Date Date 402(c) (4) (C) Jan. 1, 1999 Jan. 1, 2001 Jan. 1, 2001 414(n) (2) (C) Nov. 1, 1997 Jan. 1, 2001 Jan. 1, 2001 414(q) Nov. 1, 1997 Jan. 1, 2001 Jan. 1, 2001 414(u) Dec. 12, 1994 Jan. 1, 2001 Jan. 1, 2001 415(c) (3) (D) Dec. 31, 1997 Jan. 1, 2001 Jan. 1, 2001 …
  13. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    …96, we lack jurisdiction to abate - 8 - interest herein. See Commissioner v. McCoy , 484 U.S. 3, 7 (1987); 508 Clinton Street Corp. v. Commissioner , 89 T.C. 352, 354 (1987). Decision will be entered for respondent with respect to the deficiency, including the additional tax under sec. 72(t), and decision will be enter…
  14. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …
  15. Treas. Reg. § 54.4980B-10(b) — Interaction of FMLA and COBRA.
    IRCRegulationsDec 30, 2016
    y of FMLA leave is 12 weeks later, on April 25, 2001, and B does not return to work with X at the end of the FMLA leave. If B does not elect COBRA continuation coverage, B will not be covered under the group health plan of X as of April 26, 2001. (ii) B experiences a qualifying event on April 25, 2001, and the maximum …
  16. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    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 (…
  17. T.C. Memo. 2016-110 — Kenneth L. Mallory & Larita K. Mallory v. Commissioner
    IRCCourt RulingsJun 6, 2016
    …2000 11,000 June 27, 2000 5,000 Aug. 7, 2000 5,000 Oct. 30, 2000 10,000 Dec. 22, 2000 5,000 Feb. 8, 2001 10,000 May 8, 2001 3,000 June 6, 2001 8,000 July 16, 2001 2,500 Aug. 6, 2001 12,000 Sept. 27, 2001 2,000 Oct. 30, 2001 2,500 Dec. 12, 2001 2,000 Total (without interest) 133,800 -5- [*5] Monarch Life regularly issue…
  18. T.C. Memo. 2009-187 — Eugene & Glenda Dollander v. Commissioner
    IRCCourt RulingsAug 19, 2009related by meaning
    …al hardship is not one of the exceptions in section 72(t)(2) . See Milner v . Commissioner , T .C . Memo . 2004-111 (no "umbrella hardship exception") ; Gallagher v . Commissioner , T .C . Memo . 2001-34 ("There is, however, no hardship exception in the controlling statutes .") . . . .continued) (A) the Thrift Savings …
  19. Treas. Reg. § 54.4980B-6(c) — Electing COBRA continuation coverage.
    IRCRegulationsDec 30, 2016
    …iving employer-paid coverage under a group health plan voluntarily terminates employment on June 1, 2001. The employee is not disabled at the time of the termination of employment nor at any time thereafter, and the plan does not provide for the extension of the required periods (as is permitted under paragraph (b) of …
  20. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…