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Go to T.C. Memo. 2005-245 (not yet in the library — opens the official source)
69 documents · 0.47sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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 …
  2. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014
    ctions, Credits, etc. In petitioner's 2005 Form 1120S, petitioner showed, inter alia, that during 2005 the ESOP owned 100% of the stock of petitioner. On a date not established by the record during 2006, the ESOP in question filed Form 5500, Annual Return/Report of Employee Benefit Plan (employee benefit plan 2005 annu…
  3. Notice 2007-3 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66, 2005-2 C.B. 509, pertaining to th…
    IRCNoticesModified Jan 8, 2007
    …ibutions. (2004 C. L.). 411(d)(6): Central Laborers’ Pension Fund v. Heinz, 124 S.Ct. 2230 (2004). (2005 C. L.). Rev. Proc. 2005-23, 2005-1 C.B. 991, as modified by Rev. Proc. 2005-76, 2005-2 C.B. 1139. (2005 C. L.). Amendments to § 1.411(d)-3 of the Final Regulations were published on August 9, 2006 (71 Fed. Reg. 4537…
  4. Notice 2005-95 — Plan amendments; retroactive annuity starting date; elective deferrals. This notice clarifies the interaction of the amendment timing deadlines for plans quali…
    IRCNoticesDec 19, 2005
    of Published Guidance Deadline to Adopt Plan Amendment under Rev. Proc. 2005-66 (or Notice 2005-5) Deadline to Adopt Plan Amendment under this Notice Retroactive Annuity Starting Date July 17, 2003 Plan years beginning on or after January 1, 2004. If discretionary — end of the plan year in which plan amendment is put …
  5. Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul…
    IRCNoticesDec 27, 2005
    , not just those on the 2005 Cumulative List. The only two items on the 2005 Cumulative List that are not yet published are listed under section 402A. The Service will not review plan language for any qualification change that becomes effective, any guidance published, or any statutes enacted after December 13, 2005, u…
  6. Notice 2008-108 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the…
    IRCNoticesDec 15, 2008★ strong match
    …d shares to pay off an exempt loan as long as equal amounts are allocated to participant accounts. (2005 C. L.). Hurricane Relief: Katrina Emergency Tax Relief Act of 2005, Pub. L. 109-73. (2005 C. L.). Notice 2005-92, 2005-2 C.B. 1165. (2005 C. L.). Announcement 2005-70, 2005-2 C.B. 682. (2005 C. L.). Gulf Opportunity…
  7. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    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,
  8. Notice 2009-98 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the…
    IRCNoticesDec 28, 2009
    …d shares to pay off an exempt loan as long as equal amounts are allocated to participant accounts. (2005 C. L.). Hurricane Relief: Katrina Emergency Tax Relief Act of 2005, Pub. L. 109-73. (2005 C. L.). Notice 2005-92, 2005-2 C.B. 1165. (2005 C. L.). Announcement 2005-70, 2005-2 C.B. 682. (2005 C. L.). Gulf Opportunity…
  9. Notice 2005-84 — Minimum funding standards; disaster relief. As a result of the enactment of section 403(b) of the Katrina Emergency Tax Relief Act of 2005, the Internal Revenu…
    IRCNoticesNov 14, 2005
    2005-60, 2005-39 I.R.B. 606, which was issued on September 2, 2005, the date for performing certain acts was extended to October 31, 2005. III. RELIEF As a result of the enactment of KETRA on September 23, 2005, the October 31, 2005, date described in Notice 2005-60 for compliance with specified Code requirements was e…
  10. Rev. Proc. 2005-66 — Qualification; determination letters; staggered remedial amendment periods. This procedure contains the Service’s procedures for issuing determination letters …
    IRCRevenue ProceduresSuperseded Sep 12, 2005
    …o be used for their first submission under the six-year remedial amendment cycle. .14 In Rev. Proc. 2005-16, 2005-10 I.R.B. 674, the Service announced the opening of the initial six-year remedial amendment cycle for defined contribution pre-approved plans. As of February 17, 2005, the Service began to accept applicatio…
  11. Rev. Proc. 2007-44 — Qualification; determination letters; staggered remedial amendment periods. Rev. Proc. 2005-66, containing the Service’s procedures for issuing determination l…
    IRCRevenue ProceduresModified Jul 9, 2007
    … designed plans that take into account the requirements of EGTRRA and other items identified on the 2005 Cumulative List. .14 Notice 2005-95, 2005-2 C.B. 1172, discussed the general timing rules for plan amendments and provides that the deadlines set forth under section 5.05 of Rev. Proc. 2005-66 apply, with certain ex…
  12. Notice 2007-94 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-28 I.R.B. 54, pertaining to …
    IRCNoticesDec 17, 2007
    …d shares to pay off an exempt loan as long as equal amounts are allocated to participant accounts. (2005 C. L.). Hurricane Relief: Katrina Emergency Tax Relief Act of 2005, Pub. L. 109-73. (2005 C. L.). Notice 2005-92, 2005-2 C.B. 1165. (2005 C. L.). Announcement 2005-70, 2005-2 C.B. 682. (2005 C. L.). Gulf Opportunity…
  13. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
  14. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
  15. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  16. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8 (2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on the date which is 60 days after the later of . . . [the] earliest incident date . . …
  17. 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 .…
  18. T.C. Memo. 2011-31 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsFeb 1, 2011★ strong match
    … as respondent conceded, and (2) petitioner is liable for the deficiencies and additions to tax for 2005-2006 as respondent determined. We also conclude that petitioner is liable for a $25,000 penalty under section 6673(a) (1) in each of the consolidated cases. - 15 - We have considered all of the arguments raised by t…
  19. Ann. 2005-36 — EP opinion letters and advisory letters; GUST. This announcement is the formal closing of the GUST program for defined contribution pre-approved plans. The ann…
    IRCAnnouncementsMay 23, 2005
    Announcement 2005-36 Closing of the GUST Program for Defined Contribution Pre-Approved Plans The Service announced the opening of the initial (i.e., EGTRRA[1]) six-year amendment/approval cycle for defined contribution pre-approved (i.e., master and prototype (M&P) and volume submitter (VS)) plans in Rev. Proc. 2005-16…
  20. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…