ERISACourt RulingsFeb 22, 2000
5 and 1996 to PWBA for review and
comment.
(e) By December 31, 1998, send finalized
versions of the 1995 and 1995 summary draft Annual Reports for the Plan participants.
(f) By December 31, 1998, pay a compromised
penalty payment of $15,000.00 to the Department.
On October 16, 1998, Respondent submitted the
draft Form …
IRCCourt RulingsAug 25, 1997related by meaning
motion for costs
was filed out of time and should be "dismissed" for that reason.
We reject respondent's contention and do not consider it further.
12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA),
Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is
generally applicable to proceedings commenced after …
IRCPrivate Letter RulingsAug 27, 1999related by meaning
…Number: 199934002
Release Date: 8/27/1999
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Taxpayer's Name:
Taxpayer's Address:
Taxpayer's Ident. No.:
Taxable Years at Issue:
Date of Conference:
Legend
:
Taxpayer =
Plan =
Trust Agreement =
ISSUES
:
(1) Whether, under the rules of section 461 of the …
IRCCourt RulingsJan 27, 1998related by meaning
began on the date that the
prohibited transaction occurred, May 31, 1988, and ended on the
-14-
8
Petitioner contends that the second-tier tax of sec. 4975(b) is not applicable because of ERISA sec. 502(i), 29 U.S.C.
1132(i) (1988). ERISA sec. 502(i) provides the following:
In the case of a transaction prohibited by se…
IRCRegulationsSep 17, 2024
…3)(B). Q-8. Is there an exception to the income-inclusion rule described in A-7 of this section for 1998 conversions? A-8. Yes. In the case of a distribution (including a trustee-to-trustee transfer) from a traditional IRA on or before December 31, 1998, that is converted to a Roth IRA, instead of having the entire tax…
IRCCourt RulingsJun 18, 1997related by meaning
…t of statutes, must have been received for a
different purpose. See Flaherty v. Commissioner
, T.C. Memo.
- 10 -
1987-61 (holding that an Internal Revenue Service employee's
disability retirement annuity payments received under the Civil
IRCRegulationsMay 18, 2016
(d) (d) The rules in this A-3 are illustrated by the following examples: Example 1.In 1998, unmarried, calendar-year taxpayer B, age 60, has modified AGI of $40,000 and compensation of $5,000. For 1998, B can contribute a maximum of $2,000 to a traditional IRA, a Roth IRA or a combination of traditional and Roth IRAs. …
IRCRegulationsMay 18, 2016
…ransferred in a tax-free transfer to another Roth IRA prior to the recharacterization. Example 2.In 1998, an individual makes a $2,000 regular contribution for 1998 to his traditional IRA (FIRST IRA). Prior to the due date (plus extensions) for filing the individual's Federal income tax return for 1998, he decides that…
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 RulingsAug 13, 1990related by meaning
et interest rate for the use of money shall be the higher of the rate on the date of the prohibited transaction or the rate on the date of correction. If a prohibited transaction is not corrected within the taxable period, disqualified persons participating in the prohibited transaction become liable for a second-tier …
IRCCourt RulingsDec 29, 2008
…xes . After 2 years the law firm completed the returns and dated its preparer signature
October 19, 1998 . The Martinezes dated their signatures October
30, 1998, and they promptly filed the returns such that
respondent recorded receiving the returns on November 4, 1998 .
Regarding the final 2 years at issue, 99 percen…
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 RulingsJan 28, 2002
T.C. Memo. 2002-30
UNITED STATES TAX COURT
DREW ALLEN RAYNER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5749-00. Filed January 28, 2002.
Drew Allen Rayner, pro se.
Linda J. Wise
, for respondent.
MEMORANDUM OPINION
COLVIN, Judge
: Respondent determined that petitioner has an
income tax defi…
T.D. 9166 — Final regulations under section 9801 of the Code provide guidance on the Health Insurance Portability and Accountability Act of 1996 (HIPAA) portability requir… IRCTreasury DecisionsFeb 22, 2005
…th anniversary date preceding the enrollment date. For example, for an enrollment date of August 1, 1998, the 6-month period preceding the enrollment date is the period commencing on February 1, 1998, and continuing through July 31, 1998. As another example, for an enrollment date of August 30, 1998, the 6-month period…
IRCCourt RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…
IRCCourt RulingsMay 22, 2003
83 (all amounts are rounded).
Petitioners timely filed a 1998 Federal income tax return.
On the 1998 return, petitioners reported $32,628 on Line 16a, Total pensions and annuities, and $15,715 on Line 16b, Taxable
amount.
For the taxable year 1998, the Teachers’ Retirement System
of Louisiana issued to petitioner a For…
IRCCourt RulingsFeb 15, 2002
tioner’s 1998
Federal income tax and an addition to tax under section
6651(a)(1) of $3,433 and $321, respectively. After concessions
by the parties,
2 the issues are (1) whether petitioner is liable
for the additional tax under section 72(t) and (2) whether
petitioner is liable for the addition to tax under section
665…
IRCCourt RulingsOct 19, 2010related by meaning
… •
warnings that he was in danger of being penalized. For example,
in Mathews v. Commissioner, T.C. Memo. 2005-84, we told
petitioner:
"Even though the filing of the petition resulted in
respondent's concession of the sec. 72(t) additional tax,
IRCCourt RulingsJul 16, 2003
…uce her
workday to 4 hours.
Petitioner temporarily stopped meeting with Dr. Labovitz after July 31, 1998. Petitioner then reentered the hospital in
October 1998 and stayed there for approximately 2 weeks, after
which time she began meeting with Dr. Labovitz again. By letter
dated December 18, 1998, Dr. Labovitz stated …
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…