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.…
IRCCourt RulingsMay 8, 2006related by meaning
… could not have been determined
whether petitioner had any overpayment with respect to taxable
year 2002.
petitioner’s overpayment for 2001.
10 The disallowance of the
credit that petitioner claimed with respect to this item does not
affect the amount of petitioner’s deficiency for 2002. See sec.
6211(a) (defining a de…
IRCCourt RulingsMay 14, 2009
…petitioners provided more
than one-half of RMW's support . See Manukainiu v . Commissioner ,
T .C . Memo . 1998-90 . Accordingly, we find that petitioners are
not entitled to a dependency exemption deduction for RMW in 2002 .
To reflect the foregoing,
Decision will be entere d
under Rule 155 .
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsMay 22, 2008
…ptember 14, 2004, petitioner submitted Forms 1040, U .S . Individual Income Tax
Return, relating to 2002 and 2003 . On the 2002 Form 1040,
petitioner reported zero income and zero tax liability, and
requested an $8,610 refund . Respondent did not accept the 2002
Form 1040 as a valid return, and prepared an SFR which se…
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 (…
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…
90 FR 3667 — Prohibited Transaction Exemption (PTE) 2002-51 To Permit Certain Transactions Identified in the Voluntary Fiduciary Correction Program ERISAFinal Rules (FR)Jan 15, 2025related by meaning
…e SCC.
Other Ministerial Amendments
The Department is finalizing certain ministerial changes to PTE 2002-51 to improve readability. For example, the Department is replacing references “to sections of the Code” to instead refer to “Code section.”
Executive Order 12866 (Regulatory Planning and Review), Executive Order 14…
91 FR 9213 — Requirement To Provide Paper Statements in Certain Cases-Amendments to Electronic Disclosure Safe Harbors ERISAProposed Rules (FR)Proposed Feb 25, 2026
…eir required ERISA disclosures electronically.[3]
The first electronic safe harbor was published in 2002 (the 2002 safe harbor).[4] The 2002 safe harbor establishes tailored safeguards for electronic disclosure for two categories of participants and beneficiaries. The first category is for participants whose employment…
IRCCourt RulingsApr 25, 2011related by meaning
…not necessarily disabled within the meaning of
I
section 72(m) (7). See Kopty v. Commissioner, T.C. Memo; 2007-343
(taxpayer who received long-term disability benefits from the
U.S. Social Security Administration nct disabled within the'
meaning of section 72(m) (7)), affd. 313 Fed. Appx. 333 (D.C. Cir.
2009); see also…
IRCCourt RulingsDec 11, 2003related by meaning
… T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, affd. 774
F.2d 426 (11th Cir. 1985).
3
See, e.g., Cavanaugh v. Commissioner
, T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir.
199…
IRCCourt RulingsMar 6, 2001
v. Commissioner
, T.C. Memo. 1998-140; Reiher v.
Commissioner
, T.C. Memo. 1998-75; Easter v. Commissioner
, T.C.
Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd.
without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette
v. Commissioner
, T.C. Memo. 1997-301; Hayes v. Commissioner
, T.C.
Memo. 1…
Notice 2014-35 — This notice provides administrative relief from the penalties under §§ 6652(d), 6652(e), and 6692 of the Code for a failure to timely comply with certain annua… IRCNoticesJun 2, 2014
…nitially adopted by DOL in 1995 and was updated in a published Federal Register notice on March 28, 2002 (67 FR 15052) (2002 DOL Notice). In order to encourage voluntary compliance with the ERISA annual reporting requirements by late filers, the DFVC Program allows plan administrators who fail to file a timely annual r…
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 RulingsJan 3, 2017related by meaning
v.
Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo.
2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v.
- 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001).
While we acknowledge and are sympathetic to petitioner's financial straits, we
have no aut…
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 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
Rev. Proc. 2003-72 — EP determination letters; extension of application deadline for certain pre-approved plans. This procedure extends the deadline for filing EP determination let… IRCRevenue ProceduresSep 22, 2003
…01(b)-1(e)(3). .03 Generally, the GUST remedial amendment period ended on the later of February 28, 2002, or the last day of the first plan year beginning on or after January 1, 2001. However, Rev. Proc. 2000-20, 2000-1 C.B. 553, (as modified by Rev. Proc. 2000-27, 2000-1 C.B. 1272; Rev. Proc. 2001-55, 2001-2 C.B. 552;…
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…
IRCCourt RulingsJun 2, 2005
… 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 contribut…