IRCPrivate Letter RulingsJun 11, 2004
…'s consent to effect the change and to
prevent amounts from being duplicated or omitted.
Rev. Proc. 2002-9, 2002-1 C.B. 32, provides the exclusive procedures by which
a taxpayer may obtain the automatic consent of the Commissioner to make the changes
in method of accounting described in that revenue procedure’s APPENDI…
IRCCourt RulingsMay 19, 2011
… employees in 2000-2003.
Leading Edge did not provide health insurance benefits to its
employees in 2002-04. Leading Edge maintained a portfolio account with Advest,
Inc. From August 2003 through December 2004 Leading Edge
- 20 -
maintained a portfolio of stocks and received dividends."
Leading Edge also maintained che…
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…
IRCCourt RulingsJun 13, 2017★ strong match
that petitioner had provided to CID in the 2002 letters. Petitioner
attached copies of the 2002 letters to the 2002 Form 211. On February 3, 2003, he received a letter from the IRS Midstates Region office in Memphis, Tennessee,
verifying that the 2002 Form 211 had been received and was being evaluated.
2004
In October…
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…2006-36 I.R.B. 353; Rev. Rul. 2005-24, 2005-1 C.B. 892; Rev. Rul. 2003-102, 2003-2 C.B. 559; Notice 2002-45, 2002-2 C.B. 93; Rev. Rul. 2002-41, 2002-2 C.B. 75; Rev. Rul. 69-141, 1969-1 C.B. 48. New section 106(e) provides that a health FSA will not fail to satisfy the requirements of sections 105 or 106 merely because …
IRCCourt RulingsMar 6, 2001★ strong match
…75), affd. without published opinion 552 F.2d 368
(5th Cir, 1977); Kiourtsis v. Commissioner
, T.C. Memo. 1996-534; Fitzpatrick v. Commissioner
, T.C. Memo. 1995-548. Even after she
received the no change letter, petitioner was aware that the 1992
tax year remained open. Petitioner signed three consents to
extend the t…
IRCCourt RulingsSep 24, 2007★ strong match
…f the pension
distribution and Social Security benefits, petitioner is liable
for 'a deficiency for 2002 that net of withholding exceeds $1,000 .
And, because petitioner failed to file a 2001 Federal income tax
return, it has not been shown that he had no tax liability in
2001 .
IRCCourt RulingsJan 27, 2014
… 20%. Mr. Ries, a disqualified person, is therefore
treated as owning all of petitioner's stock for 2002. See secs. 409(p)(3),
-14- [*14] 318(a)(1)(A); sec. 1.409(p)-1(e)(2), Income Tax Regs. Accordingly, 2002 is
a nonallocation year. See sec. 409(p)(3).
D. The Plan Violated Section 409(p) for 2002.
The Plan made an im…
IRCCourt RulingsJul 13, 2010
…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 potential …
IRCCourt RulingsJan 3, 2017related by meaning
v.
Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo.
2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v.
- 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001).
While we acknowledge and are sympathetic to petitioner's financial straits, we
have no aut…
IRCCourt RulingsJan 31, 2008
…. Commissioner , 93 T .C . 181,
195 (1989) . The record establishes, and we have found, that
during 2002 Mr . Bangs paid to Ms . Platt $8,803 .87 pursuant to the
divorce decree provision in question .
Date of Payment Amount . of Paymen t
01/14/2002 728 .9 1
02/13/2002 728 .9 1
03/13/2002 728 .9 1
04/15/2002 728 .9 1
05…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsMay 29, 2002related by meaning
… however, there was no levy by respondent in this case.
Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13,
affd. without published opinion 166 F.3d 1201 (2d Cir. 1998),
also cited by petitioner, the taxpayer was indicted on charges of
violating Federal currency transaction reporting laws. As part
of the taxpaye…
IRCCourt RulingsNov 30, 2006related by meaning
…herwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979-04S. Filed…
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 .…
IRCRegulationsDec 30, 2016
…e for the year. Thus, the second condition in paragraph (c) of this Q&A-8 is also satisfied for the 2002 plan year. Because both conditions in paragraph (c) of this Q&A-8 are satisfied for 2002, with respect to any qualifying event occurring in 2002, the health FSA is not obligated to make COBRA continuation coverage a…
IRCCourt RulingsOct 19, 2010related by meaning
… •
warnings that he was in danger of being penalized. For example,
in Mathews v. Commissioner, T.C. Memo. 2005-84, we told
petitioner:
"Even though the filing of the petition resulted in
respondent's concession of the sec. 72(t) additional tax,
IRCCourt RulingsMay 8, 2006related by meaning
… could not have been determined
whether petitioner had any overpayment with respect to taxable
year 2002.
petitioner’s overpayment for 2001.
10 The disallowance of the
credit that petitioner claimed with respect to this item does not
affect the amount of petitioner’s deficiency for 2002. See sec.
6211(a) (defining a de…
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
….39
6.65
7.39
2001
October
7.37
6.64
7.37
2001
November
7.36
6.62
7.36
2001
December
7.34
6.61
7.34
2002
January
7.34
6.60
7.34
2002
February
7.33
6.60
7.33
2002
March
7.32
6.59
7.32
2002
April
7.32
6.58
7.32
2002
May
7.31
6.58
7.31
2002
June
7.30
6.57
7.30
2002
July
7.28
6.55
7.28
2002
August
7.26
6.53
7.26
2002
Septe…
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 …