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Go to T.C. Memo. 2003-289 (not yet in the library — opens the official source)
75 documents · 0.27sAllIRCERISAPBGCJoint 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. U.S. Tax Court — Andrea C. Casula v. Commissioner
    IRCCourt RulingsMay 5, 2008
    erseded by Rev . Proc . 2003-61, 2003-2 C .B . 296, which is effective as to requests for relief filed on or after Nov . 1, 2003, and for requests for relief pending on Nov . 1, 2003, as to which no preliminary determination letter had been issued as of that date . Although petitioner's application for relief was filed…
  3. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    … however, there was no levy by respondent in this case. Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13, affd. without published opinion 166 F.3d 1201 (2d Cir. 1998), also cited by petitioner, the taxpayer was indicted on charges of violating Federal currency transaction reporting laws. As part of the taxpaye…
  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. Rev. Rul. 2003-124 — Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contribu…
    IRCRevenue RulingsDec 8, 2003
    …g contributions to defined benefit plans and permitted disparity. EXEMPT ORGANIZATIONS Announcement 2003-77 Announcement 2003-77 A list is provided of organizations now classified as private foundations. ADMINISTRATIVE Notice 2003-76 Notice 2003-76 This notice sets out transactions that have been identified by the Trea…
  6. Treas. Reg. § 1.72(p)-1(b) — Loans treated as distributions.
    IRCRegulationsSep 17, 2024
    … introductory text of this section: Example.(i) A participant receives a $20,000 loan on January 1, 2003, to be repaid in 20 quarterly installments of $1,245 each. On December 31, 2003, the outstanding loan balance ($19,179) is deemed distributed as a result of a failure to make quarterly installment payments that were…
  7. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  8. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016
    120, U.S. Corporation Income Tax Return (2003 corporate return), for 2003. Petitioners filed a joint Form 1040, U.S. Individual Income Tax Return, for 2003 (2003 joint return) before April 15, 2004. They reported that they had received IRA distributions totaling $432,076.41,5 that these distributions were the subject o…
  9. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8 (2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on the date which is 60 days after the later of . . . [the] earliest incident date . . …
  10. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…
  11. 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…
  12. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    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…
  13. 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
    …adoption of good faith EGTRRA plan amendments.[4] .07 Rev. Proc. 2002-29, as modified by Rev. Proc. 2003-10, 2003-2 I.R.B. 259, provides that defined contribution plans must be amended to the extent necessary to comply with final and temporary regulations under § 401(a)(9). In general, these amendments must be adopted …
  14. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    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…
  15. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    ). VIII. Conclusion Petitioners received railroad retirement and Social Security benefits from the RRB during each of the years in issue . Petitioners have failed to prove that respondent incorrectly determined the adjustments to petitioners’ income on the basis of amounts that were not reported in the information retu…
  16. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008
    tax return relating to 2001 . In 2003, respondent prepared a substitute for return (SFR) relating to petitioner's 2001 taxable year . On September 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 t…
  17. T.C. Memo. 2010-61 — Wendy W. Bozick v. Commissioner
    IRCCourt RulingsMar 30, 2010
    …Rev . Proc . 2003-61, sec . 4 .03, 2003-2 C .B . at 298-299 . See Nihiser v . Commissioner , T .C . Memo . 2008-135 . Under this test, we look to a "nonexclusive list of factors" to determine whether "it is inequitable to hold the requesting spouse liable" : (1) Whether-the requesting spouse is separated or divorced fr…
  18. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011related by meaning
    efore the loan was not a taxable distribution in 2003. On March 21, 2006, the Air Force removed petitioner from service and 'notified the TSP. The Air Force did not reinstate petitioner within 31 days from March 21, 2006. As a result, the TSP notified petitioner that the loan provisions required repayment of the outsta…
  19. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006
    …approval), as clarified and modified by Notice 2002-72, 2002-2 C.B. 843, and modified by Rev. Proc. 2003-34, 2003-1 C.B. 856, and Rev. Proc. 2003-79, 2003-2 C.B. 1036; Rev. Proc. 2002-37, 2002-1 C.B. 1030 (certain corporations), as clarified and modified by Notice 2002-72 and modified by Rev. Proc. 2003-34; Rev. Proc. …
  20. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    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.…