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Go to T.C. Memo. 2007-147 (not yet in the library — opens the official source)
81 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 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…
  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. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM Third Party Communication: None Date of Communication: Not Applicable Number: 200648028 Release Date: 12/1/2006 Index (UIL) No.: 6166.00-00, 6403.00-00, 2055.00-00, 2511.02-00, 414 .00-00, 2053.09-00, 2032.00-00 CASE - MIS No.: TAM - 142156-05 AUGUST …
  4. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    … • warnings that he was in danger of being penalized. For example, in Mathews v. Commissioner, T.C. Memo. 2005-84, we told petitioner: "Even though the filing of the petition resulted in respondent's concession of the sec. 72(t) additional tax,
  5. 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…
  6. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    …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 depreciable only for …
  7. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    A Knighton indicated in her activity log for September 20, 2007, that she "need[ed] to research to determine of [sic] this [carryback] is acceptable." Also on September 20, 2007, RA Knighton prepared and sent an additional IDR to the Goldbergs, giving them a two-week due date "with understanding that additional time ma…
  8. Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi…
    IRCRevenue RulingsJul 17, 2006related by meaning
    hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan. ADMINISTRATIVE Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
  9. Notice 2010-90 — This notice contains the 2010 Cumulative List of Changes in Plan Qualification Requirements (2010 Cumulative List) described in section 4 of Rev. Proc. 2007-44…
    IRCNoticesDec 27, 2010
    …B. 390, provides guidance regarding HEART Act § 104(a). (New). 9. 401(k) & 401(m) [4]: Announcement 2007-59, 2007-1 C.B. 1448, provides that a plan will not fail to satisfy the requirements of a § 401(k) safe harbor plan because of a mid-year change to implement a designated Roth contribution program. (2007 C. L.). PPA…
  10. 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 …
  11. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007related by meaning
    … related to their investment in the partnerships; FPAAs were - 25 - 13 Bales v. Commissioner , T.C. Memo. 1989-568, involved deficiencies determined against various investors in several Hoyt partnerships. This Court found in favor of the investors on several issues, stating that “the transaction in issue should be resp…
  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. 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 (…
  14. Notice 2007-69 — Normal retirement age; temporary relief. This notice provides temporary relief for certain pension plans whose definition of normal retirement age may be requi…
    IRCNoticesAug 27, 2007
    ude “Notice 2007-69” in the subject line of any electronic communication. All materials submitted will be available for public inspection and copying. VII. Effect on Other Documents Rev. Proc. 2007-4 is modified. Notice 2007-3 is modified to provide that the 2007 regulations will be taken into account in the Service’s …
  15. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    limitation would have expired. - 11 - Nor does the fact that respondent had already issued petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected items notice of deficiency to petitioners for the same year. See sec. 6230(a)(2)(C); Hemmings v. Commissio…
  16. 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…
  17. Notice 2012-76 — This notice contains the 2012 Cumulative List of Changes in Plan Qualification Requirements (2012 Cumulative List) described in section 4 of Rev. Proc. 2007-44…
    IRCNoticesDec 27, 2012
    lective contributions. (2008 C. L.) Notice 2007-7, 2007-1 C.B. 395, provides guidance regarding § 411(a), as amended by § 904 of PPA ’06. (2008 C. L.) Rev. Rul. 2012-4, 2012-8 I.R.B. 386, describes whether a qualified defined benefit pension plan that accepts a direct rollover of an eligible rollover distribution from …
  18. Treas. Reg. § 1.436-1(j)(10) — Limits on benefits and benefit accruals under single employer defined benefit plans.
    IRCRegulationsSep 9, 2016
    …tion date of January 1. Section 436 applies to Plan R for 2008. The valuation interest rate for the 2007 plan year for Plan R is 7%. The fair market value of assets of Plan R as of January 1, 2007, is $1,000,000. The actuarial value of assets of Plan R as of January 1, 2007, is $1,200,000. The current liability of Plan…
  19. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025related by meaning
    Treas. Reg. § 1.482-7T(i)(6) does not operate as a safe harbor and therefore does not preclude R from making a PCT allocation under paragraph (i)(3). 6. Held, further, R did not abuse his discretion under I.R.C. § 482 by adjusting P’s and S’s RAB shares to determine the required CST p ayment. 7. Held, further, R ’s me…
  20. Rev. Proc. 2008-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section…
    IRCRevenue ProceduresSuperseded Jan 7, 2008
    …EEN MADE TO THIS PROCEDURE? In general .01 This revenue procedure is a general update of Rev. Proc. 2007-6, 2007-1 I.R.B 189, which contains the Service’s general procedures for employee plans determination letter requests. Other changes .02 In addition to minor revisions, such as updating references, the following cha…