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Go to 127 T.C. 200 (not yet in the library — opens the official source)
83 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. Rev. Proc. 2023-4 — This document updates Rev. Proc. 2022-4, 2022-1 IRB 161, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 3, 2023
    d plans 200 .15 Withdrawal of requests 200 .16 Right to status conference 200 .17 How to request status conference 200 .18 Correct format required 200 SECTION 11. WHAT IS THE PROCESS FOR REQUESTING DETERMINATION LETTERS FOR INDIVIDUALLY DESIGNED PLANS? 200 .01 Requesting determination letters 201 .02 Forms 201 .03 Appl…
  2. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    …with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax consequ…
  3. T.C. Memo. 2013-42 — Roger Phillips v. Commissioner
    IRCCourt RulingsFeb 7, 2013
    …tioner failed to prove that respondent's determination was erroneous. Petitioner's distribution of $127,074 is an early distribution from a qualified retirement plan. Accordingly, the 10% additional tax applies to the $127,074 distribution unless petitioner qualifies for an exception. See sec. 72(t)(1) and (2); see als…
  4. T.D. 10001 — These regulations provide guidance related to section 401 of the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), enacted on Dec…
    IRCTreasury DecisionsAug 12, 2024related by meaning
    isted transactions would be required to file disclosures with the IRS and would be subject to penalties for failure to disclose. T.D. 10004, page 489. This document contains final regulations regarding the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizat…
  5. 77 FR 74063 — Amendments to the Abandoned Plan Regulations
    ERISAProposed Rules (FR)Proposed Dec 12, 2012
    …e Harbor 0 0 4,480,000 4,480,000 Class Exemption Familiarization 9,400 18,700 0 28,100 Total 64,000 127,000 4,480,000 4,670,000 Notice to Plan Sponsor:
  6. Treas. Reg. § 1.72-17A(ii)(2)(iv)(A) — Special rules applicable to employee annuities and distributions under deferred compensation plans to self-employed individuals and owner-employees.
    IRCRegulationsMar 14, 2019
    … $7,500 $2,500 $900 $300 1975 7,500 2,500 4,000 1,300 1974 7,500 2,500 1,800 700 1973 2,500 2,500 1,200 1,200 1972 2,500 2,500 1,300 1,300 Totals 27,500 12,500 9,200 4,800 (2) The amount of the $54,000 distribution to which subdivision (i)(A) of this subparagraph applies is $20,000, computed as follows: X contributions…
  7. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
  8. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012★ strong match
    …ly noted, the wages listed on the census form were grossly overstated. . In each of the years 1999, 2000, 2001, and 2002, Diogenes paid $200,000 to the xélan 419 plan and the xélan 419 plan remitted equivalent payments to Indianapolis Life. Diogenes paid xélan the $600 anmial administration fee to participate in the xé…
  9. 89 FR 37706 — Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern
    IRCFinal Rules (FR)May 6, 2024
    …lls are FEOC-compliant through the physical tracking of the 4,000,000 kg of FEOC-compliant ACM-Z to 200,000 (4,000,000/20) of the battery cells that also contain battery component A, in order to determine which 200,000 battery cells are FEOC-compliant. Alternatively, M may determine which 200,000 battery cells are FEOC…
  10. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  11. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
  12. Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 2, 2024
    … determination letters 199 .02 Forms 199 .03 Application must include a copy of plan and amendments 200 .04 Restatements required 200 .05 Section 414(x) combined plans 200 SECTION 12. WHEN MAY AN ADOPTER OF A PRE-APPROVED PLAN (STANDARDIZED OR NONSTANDARDIZED) SUBMIT A DETERMINATION LETTER APPLICATION? 200 .01 Eligibil…
  13. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013related by meaning
    …. Accordingly, petitioners are liable for the section 6662(a) accuracy-related penalty for tax year 2005. All other adjustments for tax year 2005 reflected on petitioners' notice of deficiency are computational. The Court has considered all of the arguments made by the parties and, to the extent they are not addressed …
  14. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ons of the Internal Revenue Code in effect for the years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. - 3 - After concessions, the following 2 issues remain for us to resolve in the present proceeding: (1) Whether petitioner, in its taxable year ending January 30, 1988 (TYE 88…
  15. Rev. Proc. 2021-4 — This document updates Rev. Proc. 2020-4, 2020-1 I.R.B. 148, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of t…
    IRCRevenue ProceduresSuperseded Jan 4, 2021
    … 5307 filing procedures 199 .03 Additional information with respect to ESOPS submitted on Form 5307 200 .04 Deviations from language of approved plan 200 .05 Adoption of plan prior to date of plan’s letter 200 .06 Timing of determination letter applications for adopting employers of pre-approved plans 200 SECTION 14. W…
  16. 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…
  17. T.C. Memo. 2014-143 — Keith Robertson v. Commissioner
    IRCCourt RulingsJul 21, 2014
    …(a)(2) addition to tax, the IRS must introduce into evidence a tax return. Wheeler v. Commissioner, 127 T.C. 200, 208-211 (2006), aff'd, 521 F.3d 1289 (10th Cir. 2008). This can be done by introducing a copy of the SFR into evidence or by stipulation of the parties that the SFR is valid and meets the requirements of se…
  18. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
  19. Rev. Rul. 2019-6 — 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 RulingsApr 1, 2019
    …1970 2037 121,068 1971 2038 122,376 1972 2039 123,660 1973 2040 124,884 1974 2041 126,000 1975 2042 127,008 1976 2043 127,884 1977 2044 128,640 1978 2045 129,384 1979 2046 130,128 1980 2047 130,776 1981 2048 131,328 1982 2049 131,784 1983 2050 132,192 1984 2051 132,600 1985 2052 132,768 1986 and Later 2053 and Later 13…
  20. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…