IRCCourt RulingsJan 13, 2003
…. Meyer) is entitled
to alimony deductions in amounts greater than those conceded by
respondent for 1994, 1995, and 1996; (2) whether Mr. Meyer is
entitled to dependency exemptions for 1994, 1995, and 1996 for
his only child; (3) whether Mr. Meyer is entitled to a child care
credit for 1994, 1995, and 1996; (4) whether…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
IRCCourt RulingsJul 20, 2000
old at the time of the
distribution.
On or before June 12, 1994, petitioner endorsed the
Prudential check over to Ms. Jones. Ms. Jones did not deposit the IRA distribution check into an IRA or an Individual
Retirement Account.
On June 14, 1994, petitioner and Ms. Jones executed a 16page Stipulation for Judgment and Mar…
IRCCourt RulingsJan 16, 2002related by meaning
…nial of
equitable relief under the last sentence of section 66(c). Beck
- 9 -
v. Commissioner, T.C. Memo 2001-198. Here, we review
respondent's denial of equitable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
IRCCourt RulingsApr 2, 2020
on.
2. Events
Goldberg's 1994 return had been examined. We do not know if the 1994
examination occurred concurrently with the Goldbergs' 2003 and 2004 examinations, and we do not know if the 1994 examination occurred during Period
17. Buffamonte supervised the revenue agent who examined Goldberg's 1994
return. During t…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
Bill of Rights II, the Internal Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004.
SELF-EMPLOYMENT TAX T.D. 9473 T.D. 9473
Final regulations under section 6159 of the Code relate to the payment of tax liabilities in installments and reflects changes to the law made by the…
IRCRegulationsMay 18, 2016
…year of service after 1993, while retaining the one-percent formula for all years of service before 1994. Thus, the plan's amended benefit formula provides a benefit equal to the sum of the benefits determined under two benefit formulas: 0.75 percent of average annual compensation per year of service, plus 0.25 percent…
T.D. 9280 — Final regulations under section 411(d)(6) of the Code provide guidance on the application of the anti-cutback rules. IRCTreasury DecisionsSep 18, 2006related by meaning
INCOME TAX
Notice 2006-76 Notice 2006-76
This notice provides examples to illustrate and confirm the application of section 937(b) of the Code and regulations sections 1.937-2T and -3T in determining whether income is derived from sources within a U.S. possession or territory specified in section 937(a)(1) or whether i…
IRCRegulationsJan 19, 2024
(d)(8)(ii) (ii) Optional delayed effective date of Retirement Protection Act of 1994 (RPA '94)(108 Stat. 5012) rules for plans adopted and in effect before December 8, 1994. For a plan adopted and in effect before December 8, 1994, the application of the rules relating to the applicable mortality table and applicable i…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJul 31, 2000
…ear. The only persons covered by the Marlton Plan are
Dr. Lo, Ms. Lo, and Edward Lo,
21
and, during 1994, the Marlton Plan purchased a separate insurance policy on the life of each of
these persons. None of these persons, had he or she died, would
have received a death benefit under the plan equal to eight times
his or…
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 …
T.D. 9256 — Final regulations under section 417 of the Code concern content requirements applicable to explanations of qualified joint and survivor annuities and qualified… IRCTreasury DecisionsApr 17, 2006related by meaning
SPECIAL ANNOUNCEMENT
Announcement 2006-22 Announcement 2006-22
This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA program during calendar year 2005. This document does not provide guidance regarding the application of the arm’s length standa…
IRCCourt RulingsMar 6, 2001★ strong match
v. Commissioner
, T.C. Memo. 1998-140; Reiher v.
Commissioner
, T.C. Memo. 1998-75; Easter v. Commissioner
, T.C.
Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd.
without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette
v. Commissioner
, T.C. Memo. 1997-301; Hayes v. Commissioner
, T.C.
Memo. 1…
IRCCourt RulingsDec 23, 1996related by meaning
…e year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1996-556
UNITED STATES TAX COURT
ALFRED P. DUFFY, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6723-93. Filed December 23, 1996.
Alfred P. Duffy, pro se.
Judith Wilkie
, for respondent.
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
ed do not apply to requests for any documents to the extent § 6104 applies.
Statement identifying information to be deleted from public inspection
.04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
IRCCourt RulingsFeb 14, 1996
…pondent conceded the Algonquin property issue in a
settlement agreement entered into on January 24, 1994. The
parties agreed at that time to a total deficiency of $11,372.40,
which reflected an amount conceded by petitioners in their
petition as capital gain inadvertently omitted from their 1988
Federal income tax. A s…
T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer … IRCTreasury DecisionsMay 23, 2016related by meaning
ple, Deputy Commissioner for Services and Enforcement.
Approved: April 29, 2016.
Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy).
Note (Filed by the Office of the Federal Register on May 3, 2016, 4:15 p.m., and published in the issue of the Federal Register for May 5, 2016, 81 F.R. 27011)
[1] Section 20…
85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights ERISAProposed Rules (FR)Proposed Sep 4, 2020
…t of Labor, Transcript of Press Conference on Corporate Activist Role in Pension Planning (July 28, 1994), at 15-16 (then-Secretary Robert Reich stating that IB 94-2 “makes very clear that . . . pension fund managers, trustees, [and] fiduciaries have an obligation to vote proxies” unless the costs “substantially outwei…
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
addition, the notice invites comments from the public regarding all aspects of these provisions.
ADMINISTRATIVE
Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…