IRCRegulationsSep 9, 2016
r the 3 1/2-month period between April 15, 2017 and January 1, 2017 valuation date using the plan's effective interest rate, for a result of $86,620 (that is, $90,000 ÷ 1.1090(2.5/12) ÷ 1.0590(3.5/12)).(v) The remainder of the required installment that was due on April 15, 2017 without regard to the liquidity requireme…
T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont… IRCTreasury DecisionsSep 28, 2015
January 1, 2017 valuation date using the plan’s effective interest rate, for a result of $86,620 (that is, $90,000 ÷ 1.1090(2.5/12) ÷ 1.0590(3.5/12)). (v) The remainder of the required installment that was due on April 15, 2017 without regard to the liquidity requirement ($20,000) remains unpaid until the July 15, 2017…
80 FR 54374 — Determination of Minimum Required Pension Contributions IRCFinal Rules (FR)Sep 9, 2015
d the April 15, 2017 due date using the plan's effective interest rate increased by 5 percentage points (10.90%), and further discounted for the 3
1/2 -month period between April 15, 2017 and January 1, 2017 valuation date using the plan's effective interest rate, for a result of $86,620 (that is, $90,000 ÷ 1.1090(2.5/…
Notice 2017-37 — This notice contains the Cumulative List of Changes in Plan Qualification Requirements for Pre-Approved Defined Contribution Plans for 2017 (2017 Cumulative Li… IRCNoticesJul 17, 2017
…List, see https://www.irs.gov/retirement-plans/operational-compliance-list.
III. APPLICATION OF THE 2017 CUMULATIVE LIST This notice relates to the opinion letter program for pre-approved defined contribution plans. The third six-year remedial amendment cycle for pre-approved defined contribution plans began February 1…
Notice 2017-76 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for December 2017 used under § 417(e)(3)(D), the… IRCNoticesDec 26, 2017
39 I.R.B. 408, Notice 2016–54, 2016–40 I.R.B. 429, and Notice 2017–50, 2017–41 I.R.B. 280, respectively.
24-MONTH AVERAGE CORPORATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for December 2017 without adjustment for the 25-year average segment rate limits are as follows:
24-Mo…
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.
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…
IRCCourt RulingsMay 23, 2005related by meaning
’ position, we are constrained to
sustain respondent’s determination on this issue. Reviewed and
adopted as the report of the Small Tax Case Division. To reflect our disposition of the disputed issue, as well as
petitioners’ concession, see supra
note 2,
Decision will be entered
for respondent.
IRCCourt RulingsAug 31, 2021related by meaning
… in so concluding. See Pough v.
Commissioner , 135 T.C. 344, 352 (2010).
Considering the foregoing, summary judgment for respondent is appropriate
in this matter .
We have considered all of the arguments that the parties made , and to the
extent they are not addressed herein, we consider them to be moot, irrelevant, or…
Notice 2017-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2017 used under § 417(e)(3)(D), the 24-m… IRCNoticesMay 30, 2017
EMPLOYEE PLANS
Notice 2017–31 Notice 2017–31
This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2017 used under § 417(e)(3)(D), the 24-month average segment rates applicable for May 2017, and the 30-year Treasury rates. These rates reflect the applicat…
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 28, 2022related by meaning
. See FPL Grp.,
Inc. & Subs. v. Commissioner, 116 T.C. 73, 74 (2001). We may grant
summary judgment regarding an issue as to which there is no genuine dispute of material fact and a decision may be rendered as a matter of
law. Rule 121(b); Sundstrand Corp. , 98 T.C. 518, 520 (1992), aff’d , 17
F.3d 965 (7th Cir. 1994).…
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…
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…
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…
IRCCourt RulingsApr 2, 2024related by meaning
is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8
(2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on
the date which is 60 days after the later of . . . [the] earliest incident date . . …
IRCCourt RulingsApr 20, 2017related by meaning
See Parker v. Commissioner, T.C. Memo. 2012-66, 103
T.C.M. (CCH) 1321, 1323 (finding section 6201(d) inapplicable where the tax-
(continued...)
- 10 - [*10] Petitioner has not satisfied his burden of proof. He failed in his petition to
assign error to any of respondent's determinations, asserting instead that he had no…
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 …
IRCCourt RulingsMar 14, 2019related by meaning
appears on dozens of other documents in the record. In any event petitioner offered no plausible explanation about
where the money went if not to him. 4We do not believe that respondent was obligated to concede the inapplicability of the section 72(t) additional tax or the nontaxability of $737 in miscellaneous income.…
Notice 2017-45 — The notice extends temporary relief under Notice 2014–5 from section 401(a)(4) nondiscrimination testing for closed defined benefit plans through plan years be… IRCNoticesSep 18, 2017
EXEMPT ORGANIZATIONS
Announcement 2017–12 Announcement 2017–12
Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A).
EMPLOYEE PLANS
Notice 2017–45 Notice 2017–45
The notic…