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…
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 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 …
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 EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn.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 …
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…eir required ERISA disclosures electronically.[3]
The first electronic safe harbor was published in 2002 (the 2002 safe harbor).[4] The 2002 safe harbor establishes tailored safeguards for electronic disclosure for two categories of participants and beneficiaries. The first category is for participants whose employment…
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 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…
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…
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. 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…
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…
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…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns.
T.D. 9332 T.D. 9332 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…
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…
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…
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 RulingsJun 13, 2017
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…
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, 2006
…ed an automatic change procedure for obtaining a change in annual accounting period. See Rev. Proc. 2002-39, 2002-1 C.B. 1046 (general procedures for prior approval), as clarified and modified by Notice 2002-72, 2002-2 C.B. 843, and modified by Rev. Proc. 2003-34, 2003-1 C.B. 856, and Rev. Proc. 2003-79, 2003-2 C.B. 10…
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…