IRCCourt RulingsJun 6, 2016
…2000 11,000
June 27, 2000 5,000
Aug. 7, 2000 5,000
Oct. 30, 2000 10,000
Dec. 22, 2000 5,000
Feb. 8, 2001 10,000
May 8, 2001 3,000
June 6, 2001 8,000 July 16, 2001 2,500
Aug. 6, 2001 12,000
Sept. 27, 2001 2,000
Oct. 30, 2001 2,500
Dec. 12, 2001 2,000
Total (without interest) 133,800
-5-
[*5] Monarch Life regularly issue…
IRCRegulationsDec 30, 2016
…iving employer-paid coverage under a group health plan voluntarily terminates employment on June 1, 2001. The employee is not disabled at the time of the termination of employment nor at any time thereafter, and the plan does not provide for the extension of the required periods (as is permitted under paragraph (b) of …
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…
IRCCourt RulingsSep 30, 2003related by meaning
…he list
of specific exceptions to tax set forth in section 72(t)(2).
Swihart v. Commissioner
, T.C. Memo. 1998-407. Moreover, unlike
petitioners in the present case, the taxpayers in Larotonda
never
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received the funds and had no opportunity to avoid the 10-percent
premature distribution penalty under former secti…
IRCCourt RulingsOct 25, 2012
…lus any future cost of living or inflation increases permitted by the Internal Revenue Service.
The 2001 plan definition was amended effective July 1, 2001, reducing the
$200,000 limitation to amounts in excess of $150,000. The 2001 plan also defined
"compensation" to include any elective deferral and amounts contribut…
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 (…
IRCCourt RulingsMar 1, 2016
ent
correspondingly adjusted each of petitioners' 2001 returns by, inter alia,
subtracting the JVC Trust distributions from their gross incomes. These adjustments resulted in tax abatements of $14,359 for petitioner and $27,105 for
Brian L. Costello. In January 2005, petitioners signed Forms 4549 with respect to
these …
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 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…
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…
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 RulingsSep 3, 1998related by meaning
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
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 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 RulingsJun 13, 2017related by meaning
and after the effective date of section 7623(b). See Whistleblower 1133213W v. Commissioner, 142 T.C. 396. In that case we held that the determinative issue is whether the whistleblower alleged facts that, if proven, would establish
that the Commissioner proceeded against the targets using information that the
whistleb…
T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover … IRCTreasury DecisionsMar 23, 2009related by meaning
on 414(w) for the entire plan year (or the portion of the plan year that the eligible NHCEs and eligible HCEs are eligible employees under the plan)). Qualified nonelective contributions and qualified matching contributions taken into account under §1.401(k)-2(a)(6) of this Chapter or qualified nonelective contribution…
IRCCourt RulingsMay 14, 2009
… in rent and royalty losses of $13,796
._
for 1999
. Respondent's'computer printout of petitioners' 2001
Schedule E shows that petitioners did not report any rent
6 _
received, depreciation expense, or other expenses related to the
two residential rental properties but claimed .a .rent and royalty
loss of $12,480 for 2…
IRCCourt RulingsJan 3, 2011
… provided Table 2001
as a substitute for the P.S. 58 rates
In, Curc io-v . Commis s ioner , T . C . Memo 2010 -115 , we used the
rates in section 1.79-3 (d) , Income Tax Regs. as a "rough
estimate" of'the cs c life insurance protection to. decide
whether the taxpayer s expenses for fife iËsuranck Were
deductible pursua…