IRCCourt RulingsJun 17, 1997related by meaning
he penalties in
docket Nos. 2545-94 and 9230-94; an
appropriate decision for respondent
will be entered in docket No.
5754-94 as to the deficiency and the addition to tax under section
6651(a)(1) and for petitioner with
respect to the penalty
.
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
Notice 2010-15 — Miscellaneous HEART Act changes. This notice provides guidance in the form of questions and answers with respect to certain provisions of the Heroes Earnings A… IRCNoticesFeb 8, 2010
…4(a) and 105(b) of the Act.
Q-19. When must plans be amended to satisfy the requirements of section 107 of the Act? A-19. Section 72(t)(2)(G)(iv) of the Code, as amended by section 107 of the Act, generally does not affect the qualification of a retirement plan. However, the amendment to § 72(t)(2)(G)(iv) of the Code m…
Notice 2006-107 — Diversification; transition rules; defined contribution plans. This notice provides transitional rules with respect to the diversification requirements of publ… IRCNoticesModified Dec 18, 2006
…tten comments should be submitted by March 18, 2007. Send submissions to CC:PA:LPD:DRU (Notice 2006-107), Room 5203, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, D.C. 20044. Comments may be hand delivered to CC:PA:LPD:DRU (Notice 2006-107), Room 5203, Internal Revenue Service, 1111 Constitution…
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
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsOct 3, 1995related by meaning
T.C. Memo. 1995-469
UNITED STATES TAX COURT
C. MERRITT and DOROTHY PUMPHREY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13538-94. Filed October 3, 1995.
Jay Fred Cohen
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was …
IRCCourt RulingsMar 15, 2004
… request for relief from
the 10-percent tax. First, petitioners point to language in H.
Conf. Rept. 107-84, at 252-253 (2001), accompanying the Economic
Growth and Tax Relief Reconciliation Act of 2001, Pub. L. 107-16,
sec. 644, 115 Stat. 123. This legislation amended sections
402(c)(3) and 408(d)(3) to grant the Secre…
IRCCourt RulingsJul 29, 1997related by meaning
rences are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. The issues for decision are (1) whether a pension plan
distribution to petitioner is taxable pursuant to section
402(a)(1) and whether petitioner is liable for a 10-perc…
IRCCourt RulingsFeb 10, 1997
…s opinion supplements our previously filed Opinion in
Lucky Stores, Inc., & Subs. v. Commissioner
, 107 T.C. 1 (1996).
T.C. Memo. 1997-70
UNITED STATES TAX COURT
LUCKY STORES, INC., AND SUBSIDIARIES, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
*
Docket No. 4446-93. Filed February 10, 1997.
P filed a Mot…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
IRCCourt RulingsJul 31, 2000★ strong match
red all of petitioners’
arguments for contrary holdings; those arguments not discussed
herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent
necessary to reject or sustain each determination . We also have
considered all of respondent’s arguments a…
IRCCourt RulingsAug 6, 1996
…
emphasis upon words contained in Rev. Rul. 76-28, 1976-1 C.B.
106. Rev. Rul. 76-28, 1976-1 C.B. at 107, states that it "provides rules with respect to the application of section
404(a)(6) * * * in those areas where the Service has determined
that guidelines are necessary pending the issuance of
regulations." (We note …
IRCCourt RulingsOct 3, 1995related by meaning
1
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTE…
IRCCourt RulingsFeb 14, 1996
…sed." H. Rept. 96-1418, at 15 (1980); see also
United States v. 88.88 Acres of Land
, 907 F.2d 106, 107 (9th Cir. 1990); American Pacific Concrete Pipe Co., Inc. v. NLRB
, 788 F.2d
586, 590 (9th Cir. 1986); Continental Web Press, Inc. v. NLRB
,
767 F.2d 321, 322-323 (7th Cir. 1985).
To demonstrate that they each had a …
IRCCourt RulingsMay 30, 1984related by meaning
was that it was "clarifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Esta…
IRCCourt RulingsApr 2, 2020
…............. 105
S. Period 12: May 29 through June 8, 2009 . . . . . . . . . . . . . . . . . . . . 107
- 5 -
[*5] 1. Introduction...................................... 107
2. Events .......................................... 107
3. Analysis and holding............................... 109
T. Intermediary day: June 9,200…
IRCCourt RulingsJun 3, 1998related by meaning
been finalized. Moreover, even if the
proposed regulation were final, it would not, by its terms,
apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2,
1998) (regulation applies to "loans made on or after the
date that is three months after the date of publication o…
89 FR 77586 — Requirements Related to the Mental Health Parity and Addiction Equity Act IRCFinal Rules (FR)Sep 23, 2024
comparative analyses to the participants and beneficiaries will therefore be approximately $107,500. See Table 14 for calculations and burden totals. 2.4. Recordkeeping Requirement
HHS posits that plans and issuers already maintain records as part of their regular business practices. HHS therefore estimates a minimal …
IRCCourt RulingsAug 26, 1980related by meaning
th the statute and the Congress' policy.
It may be that the regulations could validly prevent such a conditioning of administrative committee consent. This is not an occasion to deliver an advisory opinion as to the validity of a hypothetical regulation, but merely an observation that the status of such a hypothetical …
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…