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…
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…
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…
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 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 (…
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 …
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 …
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…
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 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…
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…
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.…
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…
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.
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 …
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…
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…
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…
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…
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…