Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to T.C. Memo. 2012-274 (not yet in the library — opens the official source)
78 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2011-56 — Delores Chenault v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    16determination to proceed with the-proposed levy as a permissible exercise of discretion. We have considered all' arguments raised by the parties and have found those arguments not discussed here-in to be irrelevant or without merit. To reflect the foregoing, Decision will be entered for respondent.
  2. 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…
  3. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    … we will give effect to these concessions and to respondent's agreement to abate the portion of the 2012 tax attributable to those amounts. We assume that further abatements may be required with respect to self-employment tax and for portions of the sections 6651 and 6654 additions to tax. - 17 - [*17] C. Abuse of Disc…
  4. 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…
  5. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  6. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    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…
  7. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
  8. 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…
  9. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    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…
  10. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    …nal activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms that the recreational activitie…
  11. DOL Office of Administrative Law Judges — USDOL, EBSA v. PLAN ADMINISTRATOR, HOME OF ECONOMY 401(K) PLAN, HOME OF ECONOMY, INC.
    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…
  12. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    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))…
  13. 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 …
  14. 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…
  15. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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…
  16. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    under section 72(t). Consistent with a prior determination regarding the section 6015 relief, respondent also conceded that petitioner was entitled to allocate the portion of the 2008 Federal income tax liability attributable to the unreported nonemployee compensation of $16,027 from FedEx to Mr. Scarlett under section…
  17. 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…
  18. Notice 2012-67 — 2013 cost-of-living adjustments; retirements plans, etc. This notice sets forth certain cost-of-living adjustments effective January 1, 2013, applicable to the…
    IRCNoticesDec 10, 2012
    INCOME TAX Rev. Proc. 2012-46 Rev. Proc. 2012-46 General rules and specifications for substitute Form 941 and Schedule B (Form 941), and Schedule R (Form 941). This procedure provides general rules and specifications from the Service for paper and computer-generated substitutes for Form 941, Schedule B (Form 941) and S…
  19. REG-113891-07 — Part IV. Items of General Interest
    IRCProposed Rules (FR)Proposed Oct 15, 2007
    … under paragraph (e) of this section, and benefit accruals resume under Plan T beginning January 1, 2012, unless Plan T provides otherwise. Example 4. (i) The facts are the same as in Example 3, except that the enrolled actuary for the plan does not issue a certification of the AFTAP for 2011 for Plan T until February …
  20. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    nd to the extent not discussed herein we conclude that they are irrelevant, moot, or without merit. To reflect the foregoing, Decision will be entered under Rule 155.