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Go to T.C. Memo. 2005-233 (not yet in the library — opens the official source)
70 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 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 . . …
  2. Notice 2005-87 — Application of regulations under section 415; plan amendments. This notice provides that when the final regulations under section 415 of the Code are published…
    IRCNoticesDec 12, 2005
    …ners' interests in the partnership. A public hearing is scheduled for February 15, 2006. Rev. Proc. 2005-74 Rev. Proc. 2005-74 Substitute tax forms and schedules. Requirements are set forth for privately designed and printed federal tax forms and conditions under which the Service will accept computer prepared, and com…
  3. 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 …
  4. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010
    Federal rates for the relevant periods . In October 2005, when Smith withdrew from Benistar Plan, the applicable Federal rate was 3 .89 percent for a short-term loan compounded annually . Rev . Rul . 2005-66, 2005-2 C .B . 686 . Mid- and long-term rates were higher . Id . In March 2006, when Mogelefsky withdrew from B…
  5. Rev. Proc. 2005-76 — Retroactive payment of benefits; multiemployer plan; discretionary relief; extension. This procedure extends the date by which certain qualified retirement pla…
    IRCRevenue ProceduresDec 12, 2005
    -23, 2005-18 I.R.B. 991, relating to the Supreme Court decision in Central Laborers’ Pension Fund v. Heinz, 541 U.S. 739 (2004). SECTION 2. BACKGROUND Section 3.01 of Rev. Proc. 2005-23 provides that a qualified plan will not be treated as having failed to satisfy the requirements of § 401(a) of the Internal Revenue Co…
  6. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    …T.C. 732, 747 (1964), affd. on this issue 356 F.2d 883 (5th Cir. 1966); Rice v. Commissioner , T.C. Memo. 1994-204. Moreover, even if respondent should be deemed to have performed a second inspection on the bartering proceeds issue without prior notification that petitioner did not waive, invalidation of the notice of …
  7. Notice 2005-92 — Distributions; recontributions; loans; Katrina Emergency Tax Relief Act of 2005 (KETRA). This notice describes various aspects of sections 101 and 103 of KETRA…
    IRCNoticesDec 19, 2005
    …on. Example 1. Taxpayer B receives a $45,000 distribution from a section 403(b) plan on November 1, 2005. Taxpayer B is a qualified individual and treats the distribution as a Katrina distribution. Taxpayer B receives no other Katrina distribution from any eligible retirement plan in 2005. After receiving reimbursement…
  8. 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…
  9. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  10. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    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…
  11. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    …nial of equitable relief under the last sentence of section 66(c). Beck - 9 - v. Commissioner, T.C. Memo 2001-198. Here, we review respondent's denial of equitable relief under section 66(c) for abuse of discretion. Id ; see also Fernandez v. Commissioner, 114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
  12. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011
    in the record, petitioner was placed on disability, and she retired from the VA on February 10, 2005. I Petitioner was 46 years old when she retired. In 2005 petitioner received disabllity payments from the U.S. Office of Personnel Management (O?M) as follows: Date Gross payment Amount withheldi Net payment Oct. 14, 2…
  13. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026related by meaning
    B. 2026-01 143 2026-4 2026-01 I.R.B. 2026-01 160 2026-5 2026-01 I.R.B. 2026-01 258 2026-6 2026-02 I.R.B. 2026-02 314 2026-7 2026-02 I.R.B. 2026-02 316 2026-8 2026-04 I.R.B. 2026-04 380 2026-9 2026-04 I.R.B. 2026-04 393 2026-10 2026-04 I.R.B. 2026-04 394 2026-12 2026-07 I.R.B. 2026-07 535 2026-13 2026-09 I.R.B. 2026-09 …
  14. 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…
  15. 145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner
    IRCCourt RulingsJul 13, 2015related by meaning
    cipates in a reportable transaction and to each amended return that reflects that participation and send a copy of the disclosure statement to the IRS Office of Tax Shelter Analysis). Petitioners do not argue in their brief that the amended return was a "qualified amended return" within the meaning of sec. 1.6664-2(c)(…
  16. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  17. 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…
  18. Notice 2006-79 — This notice sets forth additional transition relief under section 409A. The notice generally extends through December 31, 2007, the transition relief that prev…
    IRCNoticesOct 23, 2006
    Notice 2005-1, Q&A-21 provided relief with respect to certain initial deferral elections, generally providing that certain requirements would not be applicable to elections made on or before March 15, 2005. One of the conditions of the requirement was that the plan be amended to comply with the requirements of section …
  19. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017related by meaning
    …me additional information about the tax shelter scheme to IRS and DOJ officials during the February 2005 meeting. We conclude that none of petitioner's letters or other submissions sent after that time conveyed relevant information that he had not previously provided. The only new information that petitioner submitted …
  20. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…