Notice 2012-64 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesOct 29, 2012
EMPLOYEE PLANS
Notice 2012-64 Notice 2012-64
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 October 2012; the 24-month average segment rates; the fu…
Notice 2012-43 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesJun 25, 2012
s Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
June 2012 3.88 3.49 4.08
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…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
Notice 2012-47 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesJul 30, 2012
s Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
July 2012 3.83 3.44 4.02
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…
IRCCourt RulingsSep 25, 2019related by meaning
… T.C. 518, 520
- 11 -
[*11] (1992), affd, 17 F.3d 965 (7th Cir. 1994); Murphy v. Commissioner, T.C.
Memo. 2019-72, at *7.
The regulations provide that a taxpayer has reasonable cause for failure to
timely pay a tax if "the taxpayer has made a satisfactory showing that he exercised
ordinary business care and prudence in…
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))…
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,
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…
T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner IRCCourt RulingsFeb 23, 2022
.S. Return of
Partnership Income, for its taxable year ending December 31, 2012
(original 2012 tax return), using the accrual method of accounting. On its original 2012 tax return, Hoops: (1) did not claim an ordinary
deduction of $10,673,327 relating to the deferred compensation liability,
(2) did not reduce its amoun…
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 RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
ERISACourt RulingsJun 26, 2013
…ile an IQPA report with its Form 5500 Annual Report for the 2007 and 2009 plan years. On August 27, 2012, HOE filed Answers to both penalties. On September 6, 2012, the Chief Judge
issued Notices of Docketing for both cases and assigned case numbers 2012 - RIS - 00113 and
2012 - RIS - 00114 . On October 3, 2012, EBSA f…
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 2012-53 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesAug 27, 2012
Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
August 2012 3.77 3.39 3.96
MINIMUM PRESENT VALUE SEGMENT RATES In general, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month average. For plan years beginning in 2008 through …
Notice 2012-55 — This notice provides guidance on the 25-year average segment rates that are applied to adjust the otherwise applicable 24-month average segment rates that are … IRCNoticesSep 4, 2012
…eviously issued 24-month average segment rates without adjustment, and, for plan years beginning in 2012, the adjusted 24-month average segment rates taking into account the 90-110% corridor around the 25-year average segment rates:
Table 1: Adjusted 24-Month Average Segment Rates
24-Month Average Segment Rates not Adj…
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…
IRCCourt RulingsJun 13, 2017related by meaning
JRN
T.C. Memo. 2017-112
UNITED STATES TAX COURT
WHISTLEBLOWER 19860-15W, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19860-15W. Filed June 13, 2017.
Sealed,¹ for petitioner.
Ashley M. Bender and Richard L. Hatfield, for respondent.
MEMORANDUM OPINION
KERRIGAN, Judge: This case is before the Co…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are 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…
Notice 2008-85 — This notice provides updated static mortality tables to be used in applying the minimum funding requirements to single employer defined benefit pension plans t… IRCNoticesOct 20, 2008
…00 0.400000
120 1.000000 1.000000 1.000000 1.000000 1.000000 1.000000 1.000000
Mortality tables for 2012 Valuation dates occurring during 2012 Distributions subject to § 417(e)(3) with annuity starting dates during stability periods beginning in 2012
MALE MALE MALE FEMALE FEMALE FEMALE UNISEX
Age 2012 Non-Annuitant Tab…
IRCCourt RulingsMay 8, 2006related by meaning
002, it could not have been determined
whether petitioner had any overpayment with respect to taxable
year 2002.
petitioner’s overpayment for 2001.
10 The disallowance of the
credit that petitioner claimed with respect to this item does not
affect the amount of petitioner’s deficiency for 2002. See sec.
6211(a) (defini…