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Go to T.C. Memo. 2003-91 (not yet in the library — opens the official source)
75 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. Notice 2004-34 — Minimum funding standards; interest rates; section 101 of Pension Funding Equity Act. This notice describes the method for determining the permissible range of…
    IRCNoticesMay 3, 2004
    ….23 6.51 7.23 2002 October 7.20 6.48 7.20 2002 November 7.17 6.46 7.17 2002 December 7.14 6.43 7.14 2003 January 7.11 6.40 7.11 2003 February 7.07 6.36 7.07 2003 March 7.03 6.33 7.03 2003 April 6.98 6.29 6.98 2003 May 6.94 6.25 6.94 2003 June 6.87 6.19 6.87 2003 July 6.80 6.12 6.80 2003 August 6.75 6.08 6.75 2003 Septe…
  2. 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 …
  3. 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 .…
  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. 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. PLR 200610016 — Year of Deduction
    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…
  7. 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.…
  8. 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…
  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. PLR 199934002 — Deferred Compensation
    IRCPrivate Letter RulingsAug 27, 1999related by meaning
    …Number: 199934002 Release Date: 8/27/1999 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM Taxpayer's Name: Taxpayer's Address: Taxpayer's Ident. No.: Taxable Years at Issue: Date of Conference: Legend : Taxpayer = Plan = Trust Agreement = ISSUES : (1) Whether, under the rules of section 461 of 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. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025related by meaning
    …nce by taxpayers with the tax laws.”) ; IRM 5.8.11.3.3(1) ; see also Bergevin v. Commissioner, T.C. Memo. 2008-6, 2008 W L 123931, at *9. Factors supporting (but not conclusive of) a determination that compromise would undermine compliance include, but are not limited to, whether a taxpayer has taken deliberate action …
  14. T.D. 9459 — Final regulations under sections 401(a)(9) and 403(b) of the Code permit a governmental plan to comply with the required minimum distribution rules by using a …
    IRCTreasury DecisionsOct 13, 2009related by meaning
    INCOME TAX T.D. 9459 T.D. 9459 Final regulations under sections 401(a)(9) and 403(b) of the Code permit a governmental plan to comply with the required minimum distribution rules by using a reasonable and good faith interpretation of the statute. T.D. 9461 T.D. 9461 Final regulations under section 6050P of the Code wil…
  15. 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…
  16. 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…
  17. 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…
  18. 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…
  19. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004related by meaning
    …ent’s litigating position that the distribution occurred in 2000. See Garcia v. Commissioner , T.C. Memo. 1998-203 (reaching this conclusion regarding another question and answer contained in the same proposed regulation), affd. without published opinion 190 F.3d 538 (5th Cir. 1999). Additionally, the substantially lev…
  20. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…