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…
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,…
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…
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…
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Article 18 of the 1994 U.S./French Tax Convention, rather than Article 19 in the now-superseded convention signed in 1967,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…
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…
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…
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…
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…
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…
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…
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
…
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…
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 …
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 …
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 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…
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 …
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 …
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 .…