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 RulingsJul 13, 2010★ strong match
…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 RulingsMay 11, 2006★ strong match
…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 RulingsJun 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
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Article 18 of the 1994 U.S./French Tax Convention, rather than Article 19 in the now-superseded convention signed in 1967,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…
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 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 RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
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 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 .…
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…
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 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 (…
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 RulingsMay 29, 1997related by meaning
…
prior years. Easter v. Commissioner
, 338 F.2d 968, 969-970 (4th
Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v.
Commissioner
, 55 T.C. 28, 32 (1970). We reject petitioners’
argument that an exception to this rule applies to disputes
involving $10,000 or less.
To reflect the foregoing,
Decision will be entere…
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…