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Go to T.C. Memo. 2003-313 (not yet in the library — opens the official source)
78 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 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.…
  2. 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 .…
  3. 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…
  4. 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…
  5. 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…
  6. 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…
  7. 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 (…
  8. T.C. Memo. 2010-200 — Cheryl Elizabeth & Don Edward Hill v. Commissioner
    IRCCourt RulingsSep 13, 2010related by meaning
    … a matter which is within the discretion of the Commissioner . . Colvin v . . Commissioner , T .C . Memo . 2004-67, affd . 122 Fed . Appx . 788 (5th Cir . 2005) . Furthermore,petitioners have failed to identify a ministerial or managerial delay by an IRS employee that cause d ,them to forgo making payments on their . i…
  9. 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…
  10. 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…
  11. 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 …
  12. 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 …
  13. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
  14. T.C. Memo. 2006-95 — Theodus J. Jordan v. Commissioner
    IRCCourt RulingsMay 8, 2006related by meaning
    002, it 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) (defini…
  15. 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…
  16. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011related by meaning
    …ucing activity. See, e.g., Pittman v. Commissioner, 100 F.3d 1308, 1313 (7th Cir. 1996), affg. T.C. Memo. 1995-243;
  17. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    ng warned by the Court and after having received notice from the Court in a prior case. 6 On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's position is both frivolous and groundless. Accordingly, we exercise our discretion and award a penalty t…
  18. 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…
  19. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019related by meaning
    DRC T.C. Memo. 2019-67 UNITED STATES TAX COURT MARIA SHENORAH MCCREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10129-14L. Filed June 6, 2019. Maria Shenorah McCree, pro se. Moenika N. Coleman, Linda L. Wong, Michael S. Navarro, and Cindy L. Wofford, for respondent. MEMORANDUM FINDINGS OF FA…
  20. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017related by meaning
    JRN T.C. Memo. 2017-112 UNITED STATES TAX COURT WHISTLEBLOWER 19860-15W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19860-15W. Filed June 13, 2017. Sealed,¹ for petitioner. Ashley M. Bender and Richard L. Hatfield, for respondent. MEMORANDUM OPINION KERRIGAN, Judge: This case is before the Co…