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Go to T.C. Memo. 2001-160 (not yet in the library — opens the official source)
80 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  2. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    …king account where she deposited her paychecks. During the period from July 27 through December 31, 2001, petitioner wrote checks totaling $66,082.07 drawn on the Harris Trust & Savings Bank joint checking account as follows: Date Check No. Description Amount 7/27/2001 136 Payable to: Discover $2,700.00 8/1/2001 137 Pa…
  3. T.C. Memo. 2005-133 — Gloria Yuen-Mee Ho & Alexander Chi-Shun Tsang v. Commissioner
    IRCCourt RulingsJun 2, 2005
    that they filed their petitions. Petitioners timely filed joint Federal income tax returns for 2001 and 2002. During 2001 and 2002, petitioner was an active participant in a section 403(b) employer-sponsored retirement plan through his employment with the University of Texas Medical Branch. Petitioner claimed IRA cont…
  4. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …
  5. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    …stituted a modification of the terms of the notes. We have previously noted that a technical advice memorandum is merely a ruling given to a specific taxpayer based upon the taxpayer's specific facts and is not a ruling of general application. See Golden Belt Tel. Association, Inc. v. Commissioner , 108 T.C. 498, 506 (…
  6. T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner
    IRCCourt RulingsMar 5, 2007
    …tion 6015(f), the Appeals officer said that petitioner had $1,764 of disposable income per month in 2001, and that her income had increased since then. That amount roughly equals the excess of petitioner’s monthly income (including child support) in 2001 of $4,184 over the six monthly expenses petitioner listed on May …
  7. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    other grounds, and remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206; Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 - II. Administrative Costs The administrative costs at issue are costs that petitioner incurred from the . time respondent issued the notice of deficiency up to the …
  8. T.C. Memo. 2005-192 — Arthur F. Millard v. Commissioner
    IRCCourt RulingsAug 8, 2005
    T.C. Memo. 2005-192 UNITED STATES TAX COURT ARTHUR F. MILLARD, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 3713-04. Filed August 8, 2005. Arthur F. Millard, pro se. Travis T. Vance III , for respondent. MEMORANDUM OPINION WELLS, Judge : Respondent determined a deficiency of $2,764 in petition…
  9. 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…
  10. T.C. Memo. 2006-47 — Diep N. Hoang v. Commissioner
    IRCCourt RulingsMar 20, 2006
    ICE dAL. T.C. Memo. 2006-47 UNITED STATES TAX COURT DIEP N. HOANG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4853-04. 042 Filed March 20, 2006., W. Michael Thornton. (specially recognized), for petitioner.¹ Francis C. Mucciolo and Lauren B. Epstein, for respondent. MEMORANDUM FINDINGS OF FAC…
  11. PLR 200144007 — Year of Inclusion in Gross Income
    IRCPrivate Letter RulingsNov 2, 2001
    …ued. This ruling is directed only to Agency A and applies only to the Plan submitted on January 12, 2001, as revised by the amendments submitted on July 24, 2001 and to the annuity contract submitted on January 12, 2001. In addition, no opinion is expressed regarding the recently submitted Plan amendments which are int…
  12. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    wed 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.…
  13. T.C. Summary Opinion 2008-28 — Michael J. Kulzer & Jan K. Bielman-Kulzer v. Commissioner
    IRCCourt RulingsMar 12, 2008
    …ners contend that the balance in petitioner's OCTFCU IRA was $51,118 .05 on December 1, 2001 . In a memorandum dated November 7, 2006, to respondent's attorney, petitioner attempts to explain how he had arrived at "$286,000", the account balance he used in his calculation of substantially equal periodic payments . Peti…
  14. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    nd to the extent not discussed herein we conclude that they are irrelevant, moot, or without merit. To reflect the foregoing, Decision will be entered under Rule 155.
  15. Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl…
    IRCRevenue RulingsMar 8, 2004
    …n Rev. Rul. 55-747 in determining the cost of insurance under a trust described in § 401(a). Notice 2001-10, 2001-1 C.B. 459, revoked Rev. Rul. 55-747, and provided a new table (Table 2001) to be used in valuing term life insurance coverage provided to an employee. Under Notice 2001-10, taxpayers could continue to use …
  16. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
  17. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
  18. 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…
  19. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007
    ailure to file an income tax return for 2001 and under section 6654(a) for failure - 6 - to make estimated tax payments for 2001. Respondent bears the burden of production with respect to petitioner’s liability for the additions to tax. Sec. 7491(c); Higbee v. Commissioner , 116 T.C. 438, 446-447 (2001). To meet his bu…
  20. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
    IRCCourt RulingsAug 28, 2008related by meaning
    T .C . Memo . 2008-20 4 UNITED STATES TAX-COUR T WALTER KOWSH, Petitioner v . COMMISSIONER OF . INTERNAL . REVENUE, Responden t Docket No . 15154-06 . Filed August 28, 2008 . Walter Kowsh, pro se . Michelle L . Maniscalco , for respondent . MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N KROUPA, Judge : Respondent determined…