IRCCourt RulingsFeb 9, 2023related by meaning
1984) ( stating that when comments
“brought to the attention of the agency nothing which it had not already
considered”, the agency need not respond). 2. T
hat s ome foreign legal restrictions apply only to
payments between related parties
Second, petitioner points out that two commentators explained
that some foreign …
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 RulingsAug 16, 2005★ strong match
…king account where she
deposited her paychecks.
During the period from July 27 through December 31, 2001,
petitioner wrote checks totaling $66,082.07 drawn on the Harris
Trust & Savings Bank joint checking account as follows:
Date
Check No.
Description
Amount
7/27/2001 136 Payable to: Discover $2,700.00
8/1/2001 137 Pa…
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…
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Article 18 of the 1994 U.S./French Tax Convention, rather than Article 19 in the now-superseded convention signed in 1967,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 RulingsFeb 28, 2024related by meaning
Motion. Therefore, there is no need to opine on the potential broader implications of section 6501( l )(4). As the Chief Justice (then a judge on the D.C. Circuit) has observed, where “a sufficient ground [exists] for deciding [a] case, . . . the cardinal principle of judicial restraint — if it is not
necessary to dec…
IRCCourt RulingsNov 30, 2006related by meaning
ted States
, 68 Fed. Cl.
177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States
,
supra
, at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy
, 516
U.S. 235, 252 (1996) (courts are “bound by the language of the
statute as it is written”); Badaracco v. …
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 RulingsJun 25, 2013related by meaning
n.
- 15 -
To give effect to our disposition of the disputed issue, as well as
petitioner's concession, see sap_rg note 2,
Decision will be entered for respondent as to the income tax
deficiency and for petitioner as to the
accuracy-related penalty.
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 RulingsOct 12, 1978related by meaning
…a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comment letter, there are a few allegations which are prop…
IRCCourt RulingsJan 17, 2024related by meaning
… additions to tax
and the penalties .
Currently before the Court is respondent’s Motion for Partial
Summary Judgment . H e seeks a ruling that section 4973 impo ses a
“ tax , ” not a “penalty” to which the provisions of section 6751 (b) c ould
appl y . We a gree with respondent and w ill accordingly grant his Motion.
B…
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 RulingsDec 19, 2000related by meaning
limitation would have
expired.
- 11 -
Nor does the fact that respondent had already issued
petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected
items notice of deficiency to petitioners for the same year. See
sec. 6230(a)(2)(C); Hemmings v. Commissio…
IRCCourt RulingsSep 17, 2026related by meaning
…cord before the Court was
inconsistent with the reasons set forth in the denial and did not support
summary judgment. W e have denied petitioner’s motion to compel
production of documents and now will grant the Commissioner’s motion
and sustain the IRS’s determination.
Background
The following facts are derived from th…
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 RulingsMay 23, 2005related by meaning
’ position, we are constrained to
sustain respondent’s determination on this issue. Reviewed and
adopted as the report of the Small Tax Case Division. To reflect our disposition of the disputed issue, as well as
petitioners’ concession, see supra
note 2,
Decision will be entered
for respondent.
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…