IRCPrivate Letter RulingsMar 3, 2000related by meaning
…C:EBEO:4
TL-N-4712-99
UILC: 419.00-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR
FROM: Assistant Chief Counsel (Employee Benefits and Exempt
Organizations) CC: EBEO
SUBJECT:
This Field Service Advice is in res ponse to your memorandum dated October 5,
1999. Field Service Advice is not …
IRCCourt RulingsJan 13, 2003
…r) 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 Mr. M…
IRCCourt RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003related by meaning
rders) applies for transfers, distributions, and payments made after December 31, 2001.
Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
IRCCourt RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
IRCRegulationsSep 9, 2016
…ce conditions under any plan of the employer. All other employees of Line 1 and Line 2 on March 31, 1995 are nonexcludable employees for purposes of the average benefit percentage test during the 1995 testing period.(iii) In order for Line 1 to satisfy the requirements of this paragraph (f) for 1995, the actual benefit…
IRCCourt RulingsFeb 12, 2008related by meaning
oner ,
T .C . Memo . 2004-125 .
- 6 -
Petitioner has not argued, and she has failed to
demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right .
Consequently, we must uphold TRHCA section 408 if it bears a
rational relationship to a legitimate govern…
117 T.C. No. 19 — The Board of Trustees of the Sheet Metal Workers' National Pension Fund, In Its Capacity As Plan Administrator v. Commissioner IRCCourt RulingsDec 4, 2001
to a technical advice
memorandum dated November 9, 1994 (regarding provisions not at
issue in this case), as well as to comply with amendments to the Code. The application contained the amended and restated plan
that petitioner adopted on December 22, 1994. It also contained
a copy of a proposed amendment to article 8…
IRCCourt RulingsSep 18, 1996
…t, the Transfer Refund was not a
qualified total distribution. See Wittstadt v. Commissioner
,
T.C. Memo. 1995-492, Humberson v. Commissioner
, T.C. Memo. 1995470; Pumphrey v. Commissioner
, T.C. Memo 1995-469; Dorsey v.
Commissioner
, T.C. Memo. 1995-97, affd. without published opinion
91 F.3d 129 (4th Cir. 1996); Hyl…
IRCPrivate Letter RulingsMay 4, 2001related by meaning
…30-00/CC:TEGE:EB:QP1
UILC: 4975.07-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area
Attn: Laura Beth Heisen
FROM: Michael Roach, Chief CC:TEGE:EB:QP1
SUBJECT: Adequacy of Department of Labor Notification Pursuant to
I.R.C. §4975(h)…
IRCPrivate Letter RulingsMar 10, 2006related by meaning
… 86,112 sets forth a defined set of
circumstances in which the Service may apply a technical advice memorandum (TAM)
that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer.
Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under
§ 7805(b) an Associate Chief Counsel, as…
IRCCourt RulingsJun 18, 1999related by meaning
1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard,…
IRCCourt RulingsFeb 10, 2009related by meaning
ic v . ,Commissioner , T .C . Memo . 1992--
609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . .
In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her
medical condition
. She explained at trial that although she
received treatment from doctors in 2005, she did …
IRCCourt RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…
IRCCourt RulingsMar 7, 2000
…er is liable for additions to tax under section 6654 for the failure to pay estimated taxes for
the 1995 and 1996 taxable years; (5) whether petitioner is liable
for accuracy-related penalties under section 6662(a) for the
underpayment of taxes for the 1994 and 1995 taxable years; and
(6) whether a penalty should be aw…
IRCCourt RulingsJun 4, 1997
…r similar NOA agreements are independent
contractors or employees. Mosteirin v. Commissioner
, T.C. Memo.
1995-367; Smithwick v. Commissioner
, T.C. Memo. 1993-582, affd.
per curiam sub nom. Butts v. Commissioner
, 49 F.3d 713 (11th Cir.
1995); Butts v. Commissioner
, T.C. Memo. 1993-478, affd. per
curiam 49 F.3d 713 (…
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 RulingsFeb 2, 2001
…Co Inc, SEP-IRA DTD 11/20/93".
Contributions were made to the account in the amounts of $27,500
for 1995 and $30,000 for 1996. Petitioner also paid $3,079 and
$4,570 for self-employed health insurance for 1995 and 1996.
Petitioner’s father, Peter J. Spuler, Sr. (Mr. Spuler), died
in 1995. During that year petitioner re…