Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013related by meaning
) any other matter involving a specific taxpayer under the jurisdiction of EP or EO Examinations, EP or EO Determinations, or an appeals office; or (5) processing and considering nondocketed cases of a taxpayer in an appeals office. However, they do not include cases in which the issue in the case is in a docketed case…
Notice 2007-82 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesOct 29, 2007
…de under § 430(h)(2)(G)(iv) to use the segment rates without applying the transitional rule. Notice 2007-81, this Bulletin, provides guidelines for determining the monthly corporate bond yield curve, the 24-month average corporate bond segment rates, and the funding transitional segment rates used to compute the target…
IRCCourt RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
IRCCourt RulingsFeb 28, 2024related by meaning
…er filed his income tax returns for the years at issue
on April 11, 2005, April 15, 2006, April 15, 2007, October 9, 2008, and
April 15, 2009, respectively. The Commissioner issued the Notice on
IRCCourt RulingsMay 22, 2008related by meaning
SERVIC E
T .C . Memo . 2008-14 2
UNITED STATES TAX COUR T
MICHAEL CABIRAC, Petitioner v .
COMMISSIONER OF INTERNAL RE ENUE, Responden t
Docket No . 24207-06 . Filed May 22, 2008 .
Michael Cabirac, pro se .
James H . Harris, Jr . , for respon d
MEMORANDUM FINDINGS OF FACT AND OPINIO N
FOLEY, Judge : The issues for decis…
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 …
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,
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…
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…
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…
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 …
T.D. 9256 — Final regulations under section 417 of the Code concern content requirements applicable to explanations of qualified joint and survivor annuities and qualified… IRCTreasury DecisionsApr 17, 2006related by meaning
SPECIAL ANNOUNCEMENT
Announcement 2006-22 Announcement 2006-22
This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA program during calendar year 2005. This document does not provide guidance regarding the application of the arm’s length standa…
IRCCourt RulingsNov 7, 1996related by meaning
is written, and, even if
petitioner's argument might accord with good policy, we are not
at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy
, 516
U.S.
116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing
Badaracco v. Commissioner
, 464 U.S. 386, 398 (1984))…
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…
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 …
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 …
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 …
IRCCourt RulingsSep 17, 2026related by meaning
n effect at all relevant times, regulation references are
to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure.
Served 09/17/26
2
[* 2 ] there were no changes in the IRS approach to the issue after review
of…
IRCCourt RulingsJul 6, 2022related by meaning
husband only. The notices of deficiency also determined accuracy-re lated penalties under section 6662, but respondent has conceded the
penalties .
3 [* 3 ] After a corporate reorganization in 2004, TEOHC informed petitioner that it wished to buy out his interests. Following lengthy negotiations , TEOHC a greed to pay…
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 (…