IRCCourt RulingsJul 13, 2010related by meaning
all of the contentions and arguments of
the parties that are not discussed herein, and we conclude that
they are without merit, irrelevant, or moot . "Para . 6 of the petition filed by each petitioner admits
:
"According to Section 6673, this court may penalize Petitioner up
to $25,000 for failure to complete the admin…
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
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…
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 …
Notice 2010-52 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesJul 26, 2010
EMPLOYEE PLANS
Notice 2010-52 Notice 2010-52
Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in July 2010; the 24-month average segment rates; the fundin…
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…
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…
ERISADOL Technical ReleasesMar 18, 2011
partments published interim final regulations implementing PHS Act section 2719 on July 23, 2010, at 75 FR 43330 (the 2010 interim final regulations). On September 20, 2010, the Department of Labor issued Technical Release 2010-02 (T.R. 2010-02), which set forth an enforcement grace period for compliance with certain n…
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 (…
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…
Notice 2013-84 — This notice contains the 2013 Cumulative List of Changes in Plan Qualification Requirements (2013 Cumulative List) described in section 4 of Rev. Proc. 2007–44… IRCNoticesDec 23, 2013
…to amend for § 401(a)(35) to the last day of the first plan year that begins on or after January 1, 2010. (2010 C. L.)
Final regulations under § 401(a)(35) were published on May 19, 2010. (2010 C. L.)
Notice 2013–17, 2013–20 I.R.B. 1082, provides relief from anti-cutback rules for an amendment to an ESOP to eliminate a…
IRCCourt RulingsFeb 9, 2023related by meaning
… and June
30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon
Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M.
(CCH) 1707 (a case involving tax years 1979, 1980, and
1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d
825 (5th Cir. 1996)
In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b… IRCTreasury DecisionsDec 7, 2015
grandfathered health plan:
(A) Changes effective after March 23, 2010 pursuant to a legally binding contract entered into on or before March 23, 2010; (B) Changes effective after March 23, 2010 pursuant to a filing on or before March 23, 2010 with a State insurance department; or
(C) Changes effective after March 23, 2…
Notice 2010-57 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesAug 23, 2010
EMPLOYEE PLANS
Notice 2010-57 Notice 2010-57
Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in August 2010; the 24-month average segment rates; the fund…
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. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer … IRCTreasury DecisionsMay 23, 2016related by meaning
ple, Deputy Commissioner for Services and Enforcement.
Approved: April 29, 2016.
Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy).
Note (Filed by the Office of the Federal Register on May 3, 2016, 4:15 p.m., and published in the issue of the Federal Register for May 5, 2016, 81 F.R. 27011)
[1] Section 20…
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…
IRCCourt RulingsJun 13, 2017related by meaning
and after the effective date of section 7623(b). See Whistleblower 1133213W v. Commissioner, 142 T.C. 396. In that case we held that the determinative issue is whether the whistleblower alleged facts that, if proven, would establish
that the Commissioner proceeded against the targets using information that the
whistleb…
IRCCourt RulingsApr 25, 2011related by meaning
…not necessarily disabled within the meaning of
I
section 72(m) (7). See Kopty v. Commissioner, T.C. Memo; 2007-343
(taxpayer who received long-term disability benefits from the
U.S. Social Security Administration nct disabled within the'
meaning of section 72(m) (7)), affd. 313 Fed. Appx. 333 (D.C. Cir.
2009); see also…
IRCCourt RulingsSep 28, 2011related by meaning
T.C. Summary Opinion 2011-113
UNITED STATES TAX COURT
GAIL MARIE WATSON, Petitioner v.
COMMISSIONER- OF INTERNAL REVENUE, Respondent
Docket No. 14769-10S. Filed September 28, 2011.
Gail Marie Watson, pro se . . ..
Ryan M. Wyzik, for respondent. .
DAWSON, Judge: The petition' in this case was filed pursuant
to the provi…
IRCCourt RulingsJun 28, 2010related by meaning
ibution from a
retirement plan account
; and (4) whether petitioner is liable fo r
an accuracy-related penalty pursuant to section 6662(a) . .2 When . he petitioned the Court, petitioner resided in Maryland .
FINDINGS OF FAC T
I . Petitioner's Settlement Proceed s
For 28 years petitioner worked at Anne Arundel Medical
…