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Go to T.C. Memo. 2006-229 (not yet in the library — opens the official source)
81 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    …re 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. 23979-04S. Filed November 30, 2006. William Edward and Patricia Marie …
  2. Rev. Proc. 2008-50 — This procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sectio…
    IRCRevenue ProceduresSep 2, 2008
    3% of the employee’s plan compensation for each payroll period from April 1, 2006 through December 31, 2006 (resulting in elective deferrals of $960). The employee’s plan compensation for 2006 was $40,000 ($8,000 for the first three months and $32,000 for the last nine months). Employer E made matching contributions eq…
  3. Notice 2007-94 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-28 I.R.B. 54, pertaining to …
    IRCNoticesDec 17, 2007
    2006 C. L.). 408A(e): PPA ’06 § 824 added § 408A(e) which permits rollovers to Roth IRAs from qualified plans, § 403(b) plans, and § 457 plans. (New). 411: PPA ’06 § 701 provides rules for cash balance plans and other hybrid defined benefit plans. (2006 C. L.). Notice 2007-6, 2007-3 I.R.B. 272, provides guidance regard…
  4. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    …ndent 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 has jurisdiction to review an…
  5. 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, 2006
    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…
  6. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
  7. 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 …
  8. T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner
    IRCCourt RulingsMar 5, 2007
    …lso Bartman v. Commissioner , 446 F.3d 785 (8th Cir. 2006), affg. in part and vacating in part T.C. Memo. 2004-93. However, Congress subsequently reinstated our jurisdiction to review the Commissioner’s determinations under section 6015(f) with respect to tax liability remaining unpaid on or after December 20, 2006. Ta…
  9. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …ruitless settlement". Petitioners stated that they would not be ready for trial on the November 27, 2006, scheduled date "because of petitioners' prior commitment for a family reunion in Germany." On September 1, 2006, the Court received from petitioners a document captioned "Opposition to respondent's motion to show c…
  10. PLR 200424004 — Year of Deduction
    IRCPrivate Letter RulingsJun 11, 2004related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM January 07, 2004 Number: 200424004 Release Date: 6/11/04 Third Party Contact: Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04 CASE-MIS No.: TAM- 127815-03, CC:ITA:B07 Industry Director ------------------------------------------------ Taxpayer's Name…
  11. Notice 2008-21 — Funding; effective date; proposed regulations under sections 430 and 436. This notice alerts taxpayers of a uniform effective date of certain proposed regulati…
    IRCNoticesFeb 19, 2008
    uation date for the second plan year that begins before 2008 (the 2006 plan year), including the increase in current liability for the 2006 plan year. For purposes of determining the FTAP for the 2007 plan year, the value of net plan assets is determined as the value of plan assets under § 412(c)(2) as in effect for th…
  12. Treas. Reg. § 1.403(b)-4(c)(5) — Contribution limitations.
    IRCRegulationsMay 18, 2016
    B may elect for 2006 is $15,000. Example 2.(i) Facts illustrating application of the includible compensation limitation. The facts are the same as in Example 1, except B's includible compensation is $14,000. (ii) Conclusion. Under section 415(c), contributions may not exceed 100 percent of includible compensation. Acco…
  13. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    …ndent 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 has jurisdiction to review an…
  14. Notice 2007-7 — Distribution issues; multiple issues; Pension Protection Act of 2006. This notice provides guidance in the form of questions and answers with respect to certai…
    IRCNoticesModified Jan 29, 2007
    …cial correction method that is available for a § 303 excess distribution made prior to September 1, 2006, provided that the correction is completed by March 15, 2007. Second, if correction is completed by December 31, 2007 (even if the § 303 excess distribution occurs after September 1, 2006), a plan may correct a § 30…
  15. 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…
  16. Notice 2007-67 — Section 906 of Pension Protection Act of 2006; Indian tribal governments; extension of transition relief. This notice extends the transition relief for plans o…
    IRCNoticesAug 27, 2007
    …additional transition issues need to be addressed. III. Extension of Transition Relief under Notice 2006-89 Since the issuance of Notice 2006-89, the Service and Treasury have continued to consult with Indian tribal government representatives. Based on those consultations and the comments received in response to Notice…
  17. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017★ strong match
    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…
  18. 89 FR 43675 — Prohibited Transaction Exemption 2006-06 for Services Provided in Connection With the Termination of Abandoned Individual Account Plans
    ERISAFinal Rules (FR)May 17, 2024related by meaning
    …mation collection requirements (ICRs) included in the December 12, 2012, proposed amendments to the 2006 regulations at 77 FR 74063 and the proposed amendments to the class exemption PTE 2006-06 at 77 FR 74055. At the same time, the Department also submitted the ICR to OMB in accordance with 44 U.S.C. 3507(d). The amen…
  19. U.S. Tax Court — Susan Elizabeth Machlay v. Commissioner
    IRCCourt RulingsFeb 10, 2009related by meaning
    ic v . ,Commissioner , T .C . Memo . 1992-- 609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . . In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her medical condition . She explained at trial that although she received treatment from doctors in 2005, she did …
  20. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    …is credibility. Therefore, we find that the -10Canadian property was not held for sale from October 2006 to October 2007 and was placed into service as a rental on October 7, 2006.6 Under section 1.168(i)-4(c), Income Tax Regs., when a property held for the production of income is converted to personal use, it is depre…