T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (… IRCTreasury DecisionsMar 7, 2005related by meaning
Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified.
EXEMPT ORGANIZATIONS
T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
IRCCourt RulingsJun 2, 2005
that they filed their petitions.
Petitioners timely filed joint Federal income tax returns
for 2001 and 2002. During 2001 and 2002, petitioner was an active participant in a section 403(b) employer-sponsored
retirement plan through his employment with the University of
Texas Medical Branch. Petitioner claimed IRA cont…
IRCCourt RulingsSep 17, 2026related by meaning
…cord before the Court was
inconsistent with the reasons set forth in the denial and did not support
summary judgment. W e have denied petitioner’s motion to compel
production of documents and now will grant the Commissioner’s motion
and sustain the IRS’s determination.
Background
The following facts are derived from th…
IRCCourt RulingsMay 23, 2005related by meaning
’ position, we are constrained to
sustain respondent’s determination on this issue. Reviewed and
adopted as the report of the Small Tax Case Division. To reflect our disposition of the disputed issue, as well as
petitioners’ concession, see supra
note 2,
Decision will be entered
for respondent.
IRCCourt RulingsJul 13, 2010
…its sole member . Ms . O'Boyle received nonemployee compensation from Red Barn
Actors studio during 2001 and 2002 .
Neither petitioner was employed by any third party during
2000, 2001, or 2002 .
Petitioners did not file a timely .tax return for the 2000,
2001, or 2002 tax years .
Mr . O'Boyle paid $10,000 toward his p…
IRCCourt RulingsMar 12, 2008
t the balance of his SBC
account was $286,205 .59 as of July 16, 2001, the date of the
$10,000 distribution . Similarly, the record contains page 1 of only one statement from petitioner's account with OCTFCU . The
other pages of the statement were not introduced into evidence .
On the basis of that partial statement, p…
IRCCourt RulingsOct 25, 2012
…lus any future cost of living or inflation increases permitted by the Internal Revenue Service.
The 2001 plan definition was amended effective July 1, 2001, reducing the
$200,000 limitation to amounts in excess of $150,000. The 2001 plan also defined
"compensation" to include any elective deferral and amounts contribut…
IRCCourt RulingsMay 22, 2025related by meaning
Treas. Reg. § 1.482-7T(i)(6) does
not operate as a safe harbor and therefore does not
preclude R from making a PCT allocation under paragraph
(i)(3). 6. Held, further, R did not abuse his discretion under
I.R.C. § 482 by adjusting P’s and S’s RAB shares to
determine the required CST p ayment.
7. Held, further, R ’s me…
T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner IRCCourt RulingsMar 5, 2007
…tion 6015(f), the Appeals officer said that petitioner had
$1,764 of disposable income per month in 2001, and that her
income had increased since then. That amount roughly equals the
excess of petitioner’s monthly income (including child support)
in 2001 of $4,184 over the six monthly expenses petitioner listed
on May …
IRCCourt RulingsFeb 28, 2024related by meaning
Motion. Therefore, there is no need to opine on the potential broader implications of section 6501( l )(4). As the Chief Justice (then a judge on the D.C. Circuit) has observed, where “a sufficient ground [exists] for deciding [a] case, . . . the cardinal principle of judicial restraint — if it is not
necessary to dec…
Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl… IRCRevenue RulingsMar 8, 2004
…n Rev. Rul. 55-747 in determining the cost of insurance under a trust described in § 401(a). Notice 2001-10, 2001-1 C.B. 459, revoked Rev. Rul. 55-747, and provided a new table (Table 2001) to be used in valuing term life insurance coverage provided to an employee. Under Notice 2001-10, taxpayers could continue to use …
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 RulingsAug 4, 2005
of the distribution was
used to pay qualified higher education expenses in the taxable
year 2001, the issue is whether petitioners are subject to the 10-percent additional tax under section 72(t)(1) on the remaining
$17,982.99. Petitioners resided in Liberty Township, Ohio, at
the time the petition was filed.
Backgrou…
IRCCourt RulingsMar 1, 2016
ent
correspondingly adjusted each of petitioners' 2001 returns by, inter alia,
subtracting the JVC Trust distributions from their gross incomes. These adjustments resulted in tax abatements of $14,359 for petitioner and $27,105 for
Brian L. Costello. In January 2005, petitioners signed Forms 4549 with respect to
these …
IRCCourt RulingsJun 25, 2012related by meaning
we conclude that petitioner did not substantially prevail with
respect to the most significant issue, we need not address whether respondent's
- 13 - position was substantially justified. Accordingly, we will deny petitioner's
motion.
We have considered the remaining arguments of both parties for results
contrary to th…
IRCCourt RulingsAug 1, 2005
…able portion of his
distribution check. In response, Americo sent petitioner a
letter, dated May 9, 2001, requesting petitioner to: (1) Return
the policy contract or submit written acknowledgment that the
policy had been lost or destroyed, and (2) submit written
acknowledgment of the reason or eligibility for a direct
…
IRCCourt RulingsMay 25, 2005related by meaning
…nse of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burden of proving that
there is no genuine issue…
IRCCourt RulingsJun 6, 2005
…as filed. Petitioners, Victor A. and Esther Suarez, are husband and
wife. During the year in issue (2001), they were homeowners of
property at 4934 Raffaele Drive, in Sierra Vista, Arizona. In
2001, Victor A. Suarez (hereinafter petitioner) withdrew $33,590
1
from his Individual Retirement Account (IRA). He received th…
IRCRegulationsDec 30, 2016
the remaining visits during 2001. Example 4.(i) A group health plan has a $250 annual deductible per covered individual. The plan provides that if the deductible is not satisfied in a particular year, expenses incurred during October through December of that year are credited toward satisfaction of the deductible in th…
IRCCourt RulingsApr 2, 2024related by meaning
is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8
(2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on
the date which is 60 days after the later of . . . [the] earliest incident date . . …