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Go to T.C. Summary Op. 2019-1 (not yet in the library — opens the official source)
81 documents · 0.27sAllIRCERISAPBGCJoint Board
  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, 2019★ strong match
    RMM T.C. Summary Opinion 2019-1 UNITED STATES TAX COURT CHRISTOPHER JOHN TOTTEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10691-14S. Filed January 29, 2019. Christopher John Totten, pro se. Peter T. McCary and A. Gary Begun, for respondent. SUMMARY OPINION ASHFORD, Judge: This case was hear…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …olidated return for a year is referred to as a consolidated group. 26 C.F.R. sec. 1.1502-1(h), (a) (2019). A consolidated group has only one income tax liability for the year. Sec. 1503(a); 26 C.F.R. sec. 1.1502-2(a) (2019). Each member of a consolidated group is severally liable for the income tax. Sec. 1503(a); 26 C.…
  4. Notice 2019-61 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for November 2019 used under § 417(e)(3)(D), the…
    IRCNoticesDec 2, 2019
    -41 I.R.B. 280, Notice 2018-73, 2018-40 I.R.B. 526 and Notice 2019-51, 2019-41 I.R.B. 866, respectively. 24-MONTH AVERAGE CORPORATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for November 2019 without adjustment for the 25-year average segment rate limits are as follows: 24-Mo…
  5. Notice 2019-56 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for October 2019 used under § 417(e)(3)(D), the …
    IRCNoticesNov 4, 2019
    -41 I.R.B. 280, Notice 2018-73, 2018-40 I.R.B. 526 and Notice 2019-51, 2018-41 I.R.B. 866, respectively. 24-MONTH AVERAGE CORPORATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for October 2019 without adjustment for the 25-year average segment rate limits are as follows: 24-Mon…
  6. Notice 2019-16 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for February 2019 used under § 417(e)(3)(D), the…
    IRCNoticesMar 4, 2019
    … BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for February 2019 without adjustment for the 25-year average segment rate limits are as follows: 24-Month Average Segment Rates Without 25-Year Average Adjustment Applicable Month First Segment Second Segment Third Segment February 2…
  7. Notice 2019-21 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for March 2019 used under § 417(e)(3)(D), the 24…
    IRCNoticesApr 1, 2019
    …ATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for March 2019 without adjustment for the 25-year average segment rate limits are as follows: 24-Month Average Segment Rates Without 25-Year Average Adjustment Applicable Month First Segment Second Segment Third Segment March 2019…
  8. PLR 201736022 — Exception For Certain Loans
    IRCPrivate Letter RulingsSep 8, 2017
    For the missed March 31, 2019 installment payment, the cure period ends June 30, 2019, and for the missed April 30, 2019 installment payment, the cure period ends September 30, 2019. Each missed installme nt payment is cured within that missed installment payment’s applicable cure period. The missed March 31, 2019 inst…
  9. 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…
  10. T.C. Summary Opinion 2026-8 — Peter J. Janangelo, Jr. & Mary Ann Janangelo v. Commissioner
    IRCCourt RulingsAug 27, 2026
    … th e expense information below identifying expenditures allegedly related to his attendance at the 2019 IRS Tax Forum , all labeled as “IRC# 162 expenses . ” Section 162 permits the deduction of expenses that were incurred as “traveling expenses . . . while away from home in the pursuit of a trade or business . ” § 16…
  11. Notice 2019-13 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for January 2019 used under § 417(e)(3)(D), the …
    IRCNoticesFeb 19, 2019
    …E BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for January 2019 without adjustment for the 25-year average segment rate limits are as follows: 24-Month Average Segment Rates Without 25-Year Average Adjustment Applicable Month First Segment Second Segment Third Segment January 20…
  12. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ounting method involving only one of the items or sub-methods. (4) The tax effect of any transaction to be consummated at some indefinite future time. (5) Any matter dealing with the question of whether property is held primarily for sale to customers in the ordinary course of a trade or business. (6) The tax effect of…
  13. 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…
  14. Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of…
    IRCNoticesMay 18, 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…
  15. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025related by meaning
    Treas. Reg. § 1.482-7T(i)(6) does not operate as a safe harbor and therefore does not preclude R from making a PCT allocation under paragraph (i)(3). 6. Held, further, R did not abuse his discretion under I.R.C. § 482 by adjusting P’s and S’s RAB shares to determine the required CST p ayment. 7. Held, further, R ’s me…
  16. 85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights
    ERISAProposed Rules (FR)Proposed Sep 4, 2020
    …reholders? Evidence from SEC No-Action Letter Decisions, U.S.C. CLASS Research Paper No. CLASS17-4 (2019), https://papers.ssrn.com/​sol3/​papers.cfm?​abstract_​id=​2881408, at 25; Joseph P. Kalt, L. Adel Turki, Kenneth W. Grant, Todd D. Kendall & David Molin, Political, Social, and Environmental Shareholder Resolutions…
  17. 84 FR 37508 — Definition of “Employer” Under Section 3(5) of ERISA-Association Retirement Plans and Other Multiple-Employer Plans
    ERISAFinal Rules (FR)Jul 31, 2019
    …intained by PEOs). Back to Citation 10.  The SECURE Act had originally been introduced on March 22, 2019 on a bipartisan basis by House Ways and Means Chairman Richard Neal (D-MA), Ranking Member Kevin Brady (R-TX), Rep. Mike Kelly (R-PA) and Rep. Ron Kind (D-WI). The SECURE Act contains the MEP provisions found in S. …
  18. Rev. Rul. 2016-5 — This revenue ruling provides tables of covered compensation under § 401(l)(5)(E) of the Internal Revenue Code and the Income Tax Regulations thereunder, effect…
    IRCRevenue RulingsFeb 22, 2016related by meaning
    INCOME TAX REG–100861–15 REG–100861–15 These proposed regulations cross-reference final and temporary rules that improve the operation of an existing safe harbor rule that is used for determining whether partnership allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners’ int…
  19. 85 FR 39113 — Financial Factors in Selecting Plan Investments
    ERISAProposed Rules (FR)Proposed Jun 30, 2020
    …/​files/​2018%2007%20NEPC%20ESG%20Survey%20Results%20.pdf?​t=​1532123276859. Back to Citation 38.   2019 ESG Survey, Callan Institute (2019), www.callan.com/​wp-content/​uploads/​2019/​09/​2019-ESG-Survey.pdf. Back to Citation 39.  DOL calculations are based on statistics from Private Pension Plan Bulletin: Abstract of…
  20. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    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…