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1. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
   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…
2. 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.
3. Notice 2012-76 — This notice contains the 2012 Cumulative List of Changes in Plan Qualification Requirements (2012 Cumulative List) described in section 4 of Rev. Proc. 2007-44…
   IRCNoticesDec 27, 2012
   Notice 2012-76 2012 Cumulative List of Changes in Plan Qualification Requirements I. PURPOSE This notice contains the 2012 Cumulative List of Changes in Plan Qualification Requirements (2012 Cumulative List) described in section 4 of Rev. Proc. 2007-44, 2007-2 C.B. 54. The 2012 Cumulative List is to be used by plan spo…
4. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
   IRCRegulationsSep 9, 2016
   2012, Sponsor S is deemed to elect to reduce the January 1, 2012, prefunding balance by $15,000 under section 436(f)(3). (ii) In accordance with paragraph (d)(1)(ii)(B) of this section, the deemed election to reduce the prefunding balance is deemed to occur on the first day of the plan year, and before the date of any …
5. Treas. Reg. § 1.436-1(h)(5) — Limits on benefits and benefit accruals under single employer defined benefit plans.
   IRCRegulationsSep 9, 2016
   he AFTAP for 2012 or until paragraph (h)(3) of this section applies on the first day of the 10th month of the plan year. Because the presumed AFTAP is 72%, Plan T is no longer subject to the restrictions on prohibited payments under paragraph (d)(1) of this section, and Plan T must provide benefits for any unpredictabl…
6. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
   IRCRevenue ProceduresJan 2, 2013related by meaning
   the Code. Both sections 18 and 19 describe generally the effect of § 7805(b) relief. Generally applied retroactively to modify or revoke prior TAM .03 A holding that modifies or revokes a holding in a prior TAM is applied retroactively, with one exception. If the new holding is less favorable to the taxpayer than the e…
7. Notice 2012-61 — This notice provides guidance on the special rules relating to pension funding stabilization for single employer defined benefit pension plans under amendments…
   IRCNoticesOct 15, 2012
   … Schedule SB reflect (1) any elections to redesignate contributions made on or before September 30, 2012, to the 2012 plan year which were originally designated as applying to the 2011 plan year in accordance with Q&A T-2(c)(2) of this notice or (2) any section 436 contributions that were made on or before September 30…
8. 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 …
9. Rev. Rul. 2012-5 — 2012 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2012 are provided for use in …
   IRCRevenue RulingsJan 30, 2012
   …with respect to organizational actions that affect the basis of the stock. EMPLOYEE PLANS Rev. Rul. 2012-5 Rev. Rul. 2012-5 2012 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2012 are provided for use in determining contributions to defined …
10. T.C. Memo. 2023-141 — Danielle Monique Scott v. Commissioner
    IRCCourt RulingsNov 28, 2023related by meaning
    …ioner did not respond t o our Order by the October 2, 2023, deadline or subsequently. Discussion I. Summary Judgment The purpose of summary judgment is to expedite litigation and avoid costly, time-consuming, and unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). T he Court may grant summar…
11. Notice 2012-56 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesSep 24, 2012
    …Segment Rates First Segment Second Segment Third Segment 1.75 4.62 5.72 For plan years beginning in 2012, the 24-month average segment rates determined under § 430(h)(2)(C)(iv) must be not less than 90% nor greater than 110% of the 25-year average segment rates. Pursuant to Notice 2012-55, I.R.B. 2012-36, the first, se…
12. Notice 2012-66 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesDec 3, 2012
    …Segment Rates First Segment Second Segment Third Segment 1.69 4.53 5.60 For plan years beginning in 2012, the 24-month average segment rates determined under § 430(h)(2)(C)(iv) must be not less than 90% nor greater than 110% of the 25-year average segment rates. Pursuant to Notice 2012-55, 2012-36 I.R.B. 332, the first…
13. 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…
14. Notice 2012-78 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesDec 27, 2012
    …Segment Rates First Segment Second Segment Third Segment 1.66 4.47 5.52 For plan years beginning in 2012, the 24-month average segment rates determined under § 430(h)(2)(C)(iv) must be not less than 90% nor greater than 110% of the 25-year average segment rates. Pursuant to Notice 2012-55, 2012-36 I.R.B. 332, the first…
15. 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…
16. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    … we will give effect to these concessions and to respondent's agreement to abate the portion of the 2012 tax attributable to those amounts. We assume that further abatements may be required with respect to self-employment tax and for portions of the sections 6651 and 6654 additions to tax. - 17 - [*17] C. Abuse of Disc…
17. Notice 2012-16 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesFeb 27, 2012
    ginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% February 2012 4.04 3.64 4.25 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
18. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    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.
19. Notice 2012-24 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesMar 26, 2012
    Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% March 2012 4.00 3.60 4.20 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
20. Notice 2012-28 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesApr 23, 2012
    Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% April 2012 3.97 3.57 4.17 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…