Search the Pension Law Library

1. Rev. Proc. 2006-27 — Administrative programs; correction programs. This procedure updates and expands upon the Service’s comprehensive Employee Plans Compliance Resolution System (…
   IRCRevenue ProceduresSuperseded May 30, 2006
   3% of the employee’s plan compensation for each payroll period from April 1, 2003 through December 31, 2003 (resulting in elective deferrals of $960). The employee’s plan compensation for 2003 was $40,000 ($8,000 for the first three months and $32,000 for the last nine months). Employer E made matching contributions eq…
2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023related by meaning
   foreign legal restrictions. See Temp. Treas. Reg. § 1.482-1T. The preamble to these temporary regulations specifically addressed the 1986 amendment to section 482 and the accompanying legislative history. T.D. 8470, 58 Fed. Reg. 5264, (Jan. 21, 1993). The 1993 Notice of Proposed Rule making (1993 Notice) included as pr…
3. T.D. 9081 — REG-129709-03 Temporary and proposed regulations under section 409(p) of the Code provide guidance concerning the requirements for employee stock ownership pla…
   IRCTreasury DecisionsSep 2, 2003★ strong match
   …f the full funding limitation of section 412(c)(7) of the Code are set forth. ADMINISTRATIVE Notice 2003-59 Notice 2003-59 Uniform capitalization; methods of accounting. This notice modifies Notice 2003-36 to permit certain taxpayers to use the automatic approval procedures of Rev. Proc. 2002-9 to change their method o…
4. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
   IRCCourt RulingsJan 14, 2013
   …Inc., concedes that it is not entitled to deduct repairs and maintenance expenses of $2,954 for the 2003 tax year. This petitioner concedes that it is not entitled to deduct rental expenses of $2,800 and $7,100 for the 2003 and 2005 tax years, respectively. Respondent concedes that this petitioner is entitled to deduct…
5. U.S. Tax Court — Cynthia M. Martinez v. Commissioner
   IRCCourt RulingsDec 29, 2008
   mmissioner's denials . Washington v . Commissioner , supra at 147-152 . A . Rev . Proc . 2003-61, Sec . 4 .01--Threshold Criteria for Granting Relie f The review process begins with seven threshold criteria that a taxpayer must satisfy before the Commissioner will consider equitable relief . Rev . Proc . 2003-61, sec .…
6. 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…
7. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
   IRCCourt RulingsMay 19, 2011
   … employees' length of employment also became a problem for employees who were buying houses. During 2003 Weekend Warrior made the following payments by check to Leading Edge for management and design services: Date Amount Aug. 15, 2003 $100,000 August 2003 200,000 Aug. 21, 2003 100,000 Aug. 31, 2003 400,000 Oct. 3, 200…
8. Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi…
   IRCRevenue RulingsJul 17, 2006related by meaning
   …(W-t-W) tax credit. This document sets forth the conclusions of the IRS study relating to Rev. Rul. 2003-112 and announces that no credit will be allowed by the Service for any WOTC and W-t-W tax credit claims without proper certification by a designated local agency in accordance with the statute.
9. T.C. Memo. 2010-20 — Gregory A. & Carolyn S. Prough v. Commissioner
   IRCCourt RulingsFeb 3, 2010
   …es of 3 .68 percent and 3 .06 percent, reflecting 120 percent of the Federal midterm rates for June 2003 and July 2003 . See Rev . Rul . 2003-60, 2003-1 C .B . 987, 988 ; Rev . Rul . 2003-71, 2003-2 C .B . 1, 2 . Respondent determined the maximum monthly distribution amount from the Jefferso n National annuity under th…
10. 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 …
11. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    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.
12. T.C. Summary Opinion 2007-168 — Cheryl Kunsman v. Commissioner
    IRCCourt RulingsSep 24, 2007
    on the joint return . Therefore, Rev . Proc . 2003-61, sec . 4 .02, does not apply . Rev . Proc . 2003-61, sec . 4 .03, 2003-2 C .B . at 298, provides a nonexclusive list of factors respondent considers in evaluating whether it would be inequitable to hold petitioner liable for all or part of an unpaid income tax liabi…
13. 89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction
    IRCProposed Rules (FR)Proposed Mar 25, 2024
    … the trust instrument generally resembles one of the eight sample CRAT forms provided in Rev. Proc. 2003-53, 2003-2 C.B. 230; Rev. Proc. 2003-54, 2003-2 C.B. 236; Rev. Proc, 2003-55, 2003-2 C.B. 242; Rev. Proc. 2003-56, 2003-2 C.B. 249; Rev. Proc. 2003-57, 2003-2 C.B. 257; Rev. Proc. 2003-58, 2003-2 C.B. 262; Rev. Proc…
14. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    ibed guidelines in Rev. Proc. 2003-61, 2003-2 C.B. 296, 8 to - 18 - 8 (...continued) 1 C.B. 447, and is effective either for requests for relief filed on or after Nov. 1, 2003, or for requests for which no preliminary determination letter was issued as of Nov. 1, 2003. In the present case, the request for relief was st…
15. T.C. Summary Opinion 2005-126 — Carolyn A. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    …liability. As directed by section 6015(f), the Commissioner has prescribed guidelines in Rev. Proc. 2003-61, 2003-2 C.B. 296, 9 to be considered in determining whether an individual qualifies for relief under section 6015(f). Rev. Proc. 2003-61, sec. 4.01, 2003-2 C.B. at 297, lists seven conditions which must be satisf…
16. 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…
17. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    $1,175 163 98 59 59 29 Concedes Equipment--Krom. 4/15/2003 7,000 7,000 -- -- -- A Equipment--Henn. 6/18/2003 15,825 15,825 -- -- -- A 4630 Equipment-- Cherokee 7/15/2003 15,000 15,000 -- -- -- -- -- B Equipment--Henn. 7/23/2003 3,200 3,200 -- -- -- B TC Equipment-- Henn. 8/1/2003 13,750 13,750 -- -- -- -- -- B Equipmen…
18. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    to "provide[] for a self-certification procedure" and to modify Rev. Proc. 2003-16, supra, "by providing that the Internal Revenue Service may grant a waiver during an examination". But these two purposes are accomplished in different ways. Whereas section 3 of Rev. Proc. 2016-47, 2016-37 I.R.B. at 347, provides for a …
19. T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen…
    IRCTreasury DecisionsFeb 26, 2007related by meaning
    addition, the notice invites comments from the public regarding all aspects of these provisions. ADMINISTRATIVE Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…
20. 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
    ….23 6.51 7.23 2002 October 7.20 6.48 7.20 2002 November 7.17 6.46 7.17 2002 December 7.14 6.43 7.14 2003 January 7.11 6.40 7.11 2003 February 7.07 6.36 7.07 2003 March 7.03 6.33 7.03 2003 April 6.98 6.29 6.98 2003 May 6.94 6.25 6.94 2003 June 6.87 6.19 6.87 2003 July 6.80 6.12 6.80 2003 August 6.75 6.08 6.75 2003 Septe…