IRCCourt RulingsFeb 9, 2023related by meaning
9 th Cir. 2012) .
329
To summarize, Thompson , the only case the opinion of the Court
cites in support of its “significant comments” holdings, in fact contradicts the opinion’s conclusion. And the opinion’s repeated
assertion that “Treasury was aware” of the points made by comments,
see op. Ct. p. 2 69 , has no legal s…
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 RulingsJan 29, 2019related by meaning
made by the parties and, to the
extent they are not addressed herein, we find them to be moot, irrelevant, or
without merit.
To reflect the foregoing, Decision will be entered under
Rule 155.
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Article 18 of the 1994 U.S./French Tax Convention, rather than Article 19 in the now-superseded convention signed in 1967,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…
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…
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 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 …
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006related by meaning
f an intangible property right; (ii) the transfer of that intangible property right; or (iii) the securitization of the intangible property right.
(4) Section 79.—Group-Term Life Insurance Purchased for Employees.—Whether a group insurance plan for 10 or more employees qualifies as group-term insurance, if the amount o…
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…
T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (… IRCTreasury DecisionsMar 7, 2005related by meaning
Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified.
EXEMPT ORGANIZATIONS
T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
ic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act. EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F…
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 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. …
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…
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 25, 2013related by meaning
T.C. Summary Opinion 2013-51
UNITED STATES TAX COURT
MARTIN TOOMBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27665-10S. Filed June 25, 2013.
James O. Creech III, for petitioner.
Thomas D. Yang, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
p…
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 9, 2002related by meaning
e underpayment which is attributable
to any substantial understatement of income tax. Sec.
6662(b)(2). A “substantial understatement” exists where the amount of the understatement exceeds the greater of 10 percent of
the tax required to be shown on the return for the taxable year
or $5,000. Sec. 6662(d)(1).
No penalty …