Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U… IRCNoticesApr 21, 2014
…uired to be operated in a manner that reflects the outcome of Windsor and the guidance in Rev. Rul. 2013–17? A–2. Qualified retirement plan operations must reflect the outcome of Windsor as of June 26, 2013. A retirement plan will not be treated as failing to meet the requirements of section 401(a) merely because it di…
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 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…
IRCCourt RulingsFeb 28, 2024related by meaning
Motion. Therefore, there is no need to opine on the potential broader implications of section 6501( l )(4). As the Chief Justice (then a judge on the D.C. Circuit) has observed, where “a sufficient ground [exists] for deciding [a] case, . . . the cardinal principle of judicial restraint — if it is not
necessary to dec…
Rev. Proc. 2015-27 — This revenue procedure contains modifications to Revenue Procedure 2013–12, 2013–4 I.R.B. 313. The modifications reflected in this revenue procedure include mi… IRCRevenue ProceduresApr 20, 2015
…nt benefits on a tax-favored basis. The most recent restatement of EPCRS is set forth in Rev. Proc. 2013–12, 2013–4 I.R.B. 313. The modifications to Rev. Proc. 2013–12 reflected in this revenue procedure include miscellaneous changes made to improve EPCRS, such as reducing VCP compliance fees relating to failures to me…
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…
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.
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
2013. The Final Rule was published in the
Federal Register
on February 13, 2013, and is effective on January 18, 2014.
See78 FR 10368 (Feb. 13, 2013). The preamble to the January 2013 Final Rule stated that the Agencies would consider exemptions for three additional types of transactions that commenters requested the A…
Notice 2013-58 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in September 2013; the 24-month average segment rat… IRCNoticesSep 30, 2013
…ding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from August 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of August 2013 are, respectively, 1.36, 4.60, and 5.58. For plan years beginning on or after January 1, 201…
Ann. 2013-15 — This announcement contains a revised Exhibit: Sample Notice to Interested Parties, attached to Rev. Proc. 2013-6, 2013-1 I.R.B. 198. The Exhibit is revised to … IRCAnnouncementsMar 11, 2013
Announcement 2013-15
This announcement contains a revised Exhibit: Sample Notice to Interested Parties, attached to Rev. Proc. 2013-6, 2013-1 I.R.B. 198. The Exhibit is revised to include the correct addresses for submitting applications for determination letters and comments submitted by interested parties, in accorda…
Notice 2013-23 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesApr 15, 2013
…e to the delayed publication of some IRS forms relating to the 2012 tax year.
EMPLOYEE PLANS
Notice 2013-23 Notice 2013-23 Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for pla…
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014related 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…
Notice 2013-66 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in October 2013; the 24-month average segment rates… IRCNoticesNov 12, 2013
…g target. Pursuant to Notice 2007–81, the monthly corporate bond yield curve derived from September 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of September 2013 are, respectively, 1.40, 4.66, and 5.62. For plan years beginning on or after January 1, …
Notice 2013-75 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesDec 2, 2013
…ing target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from October 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of October 2013 are, respectively, 1.24, 4.47, and 5.52. For plan years beginning on or after January 1, 20…
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…
Notice 2013-85 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in December 2013; the 24-month average segment rate… IRCNoticesDec 23, 2013
…ng target. Pursuant to Notice 2007–81, the monthly corporate bond yield curve derived from November 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of November 2013 are, respectively, 1.19, 4.53, and 5.66. For plan years beginning on or after January 1, 2…
Notice 2014-48 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for July 2014 used under § 417(e)(3)(D), the 24-… IRCNoticesSep 2, 2014
…ctions, and transition issues.
EFFECT ON OTHER DOCUMENTS
The following Notices are modified:
Notice 2013–11, 2013–11 I.R.B. 610,
Notice 2013–23, 2013–16 I.R.B. 906,
Notice 2013–28, 2013–19 I.R.B. 1039,
Notice 2013–32, 2013–22 I.R.B. 1137,
Notice 2013–37, 2013–26 I.R.B. 1269,
Notice 2013–46, 2013–31 I.R.B. 117,
Notice 2…
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…
Ann. 2013-13 — This announcement contains corrections to Revenue Procedure 2013-6, 2013-1 I.R.B. 198, as published on January 2, 2013. In particular, this announcement clarif… IRCAnnouncementsFeb 25, 2013
Announcement 2013-13
This announcement contains corrections to Revenue Procedure 2013-6, as published on January 2, 2013 (2013-1 I.R.B. 198). In particular, this announcement clarifies that applications for determination letters should continue to be submitted to the Covington, KY address in section 6.15 of Rev. Proc. …
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…