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Go to T.C. Memo. 2008-115 (not yet in the library — opens the official source)
79 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 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
    …ect to which the requirements of § 401(m)(12) are met in the list of plans that are not top heavy. (2008 C. L.) 417: PPA ’06 § 1102(a) provides that notice required to be provided under § 417 may be provided as much as 180 days before the annuity starting date.[9] (2008 C. L.) Notice 2007-7, 2007-1 C.B. 395, provides g…
  3. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    oner , T .C . Memo . 2004-125 . - 6 - Petitioner has not argued, and she has failed to demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right . Consequently, we must uphold TRHCA section 408 if it bears a rational relationship to a legitimate govern…
  4. Notice 2008-45 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesApr 28, 2008
    Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% April 2008 4.78 4.30 5.02 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
  5. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    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…
  6. Notice 2008-50 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesMay 27, 2008
    rs Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% May 2008 4.76 4.29 5.00 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
  7. Notice 2008-53 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesJun 30, 2008
    s Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% June 2008 4.75 4.28 4.99 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
  8. Notice 2008-62 — This notice provides that the Treasury Department and the IRS anticipate proposing regulations that will address, among other things, when an arrangement in wh…
    IRCNoticesJul 21, 2008
    …t exceed the dollar amount under § 402(g)(1)(B) applicable for the first calendar year ($15,500 for 2008). For example, assume a school district employee works during a school year that begins on August 1, 2008 and ends on May 31, 2009 (a 10-month school year). Assume further that the employee is paid over the 12-month…
  9. 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…
  10. Notice 2008-65 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesJul 28, 2008
    s Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% July 2008 4.74 4.27 4.98 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
  11. Notice 2009-98 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the…
    IRCNoticesDec 28, 2009
    … be provided under § 417 may be provided as much as 180 days before the annuity starting date.[12] (2008 C. L.). Notice 2007-7, 2007-1 C.B. 395, provides guidance regarding PPA ’06 § 1102. (2008 C. L.). PPA ’06 § 302(b) amended the applicable interest rate and mortality table to be used for determining the present valu…
  12. T.C. Memo. 2017-136 — David D. Pritchard v. Commissioner
    IRCCourt RulingsJul 10, 2017related by meaning
    … distribution.3 On the record before us, we find that petitioners are liable for their taxable year 2008 for the 10-percent additional tax imposed by section 72(t)(1) with respect to their retirement distribution. We have considered all of the contentions and arguments of petitioners that are not discussed herein, and …
  13. Notice 2008-69 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesAug 25, 2008
    Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% August 2008 4.73 4.25 4.96 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
  14. T.C. Memo. 2015-119 — Clement C. Benenson v. Commissioner
    IRCCourt RulingsJun 29, 2015
    . Clement filed timely a Form 1040 for tax year 2008. He reported $518,722 of gross income on his 2008 Form 1040. He did not attach a Form 5329, _ 9 _ [*9] Additional Taxes on Qualified Plans (Including IRAs) and Other TaxFavored Accounts. James III filed timely a Form 1040 for tax year 2008. He reported $526,528 of gr…
  15. 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
    f the adopted TAM to the taxpayer, or at the end of the 30-day period following the issuance of the TAM to the field. Discussion with the taxpayer .03 EP or EO Technical will not discuss the contents of the TAM with the taxpayer or the taxpayer’s representative until the taxpayer has been given a copy by the EP or EO E…
  16. 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…
  17. 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 (…
  18. Treas. Reg. § 1.415(f)-1(j) — Aggregating plans.
    IRCRegulationsSep 9, 2016
    ection 415(c) and § 1.415(c)-1. On July 15, 2008, F dies, and A inherits all of F's stock in Z in 2008. (ii) Conclusion. As of July 15, 2008, A is considered to be in control of X and Z Corporations, and the two plans must be aggregated for purposes of applying the limitations of section 415. However, even though A's t…
  19. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    , or documents to which §6104 (document open to public inspection) applies, as described in section 10.03. Taxpayer may protest deletions not made .05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
  20. Notice 2011-96 — This notice provides a sample plan amendment that plan sponsors may adopt to satisfy section 436 of the Code regarding limitations on the accrual and payment o…
    IRCNoticesModified Dec 27, 2011
    …), (h)(2), and (i) were published in the Federal Register on December 31, 2007, 72 FR 74215. Notice 2008-21, 2008-1 C.B. 431, provides that when the proposed regulations under §§ 430 and 436 are finalized, the final regulations will not apply to plan years beginning before January 1, 2009. Notice 2008-21 further provid…