IRCCourt RulingsJun 25, 2013related by meaning
T.C. Summary Opinion 2013-51
UNITED STATES TAX COURT
MARTIN TOOMBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27665-10S. Filed June 25, 2013.
James O. Creech III, for petitioner.
Thomas D. Yang, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
p…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…ed an automatic change procedure for obtaining a change in annual accounting period. See Rev. Proc. 2002-39, 2002-1 C.B. 1046 (general procedures for prior approval), as clarified and modified by Notice 2002-72, 2002-2 C.B. 843, and modified by Rev. Proc. 2003-34, 2003-1 C.B. 856, and Rev. Proc. 2003-79, 2003-2 C.B. 10…
IRCCourt RulingsMay 14, 2009
…- support furnished to RMW from all sources in 2002 . The only
evidence petitioners proffered was a summary of expenses
estimating their dependent care expenses at $9,483 and a
statement allegedly made by RMW that she received her financia l
support from Mrs . Steele in 2002 . Petitioners testified that RMW
also reside…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
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 RulingsSep 24, 2007
him . On May 24, 2002,
SBC Communications, Inc ., issued a check to petitioner in the
amount of $131,317 .46 . The gross amount of the check had been $168,355 .71 . However, $33,671 .14 in Federal income tax and
$3,367 .11 in California State income tax had been withheld .
During 2002, petitioner also received $9,552 …
IRCCourt RulingsNov 7, 2003related by meaning
…ubsequent section
references are to the Internal Revenue Code in effect for the
year at issue.
T.C. Summary Opinion 2003-161
UNITED STATES TAX COURT
MARTIN EDWARD CAULFIELD, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19485-02S. Filed November 7, 2003.
Martin Edward Caulfield, pro se.
James L…
85 FR 31884 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAFinal Rules (FR)May 27, 2020
…ectronically. The preamble to the Department's proposal of this regulation included a comprehensive summary of the 2002 safe harbor's requirements.[4]
IRCCourt RulingsMay 22, 2008
…ptember 14, 2004, petitioner submitted Forms 1040, U .S . Individual Income Tax
Return, relating to 2002 and 2003 . On the 2002 Form 1040,
petitioner reported zero income and zero tax liability, and
requested an $8,610 refund . Respondent did not accept the 2002
Form 1040 as a valid return, and prepared an SFR which se…
IRCCourt RulingsNov 28, 2023related by meaning
…ioner did not respond t o our Order by the October 2, 2023, deadline or subsequently.
Discussion
I. Summary Judgment The purpose of summary judgment is to expedite litigation and
avoid costly, time-consuming, and unnecessary trials. Fla. Peach Corp.
v. Commissioner , 90 T.C. 678, 681 (1988). T he Court may grant summar…
145 T.C. No. 1 — John A. Tomassetti & Cathy C. Tomassetti v. Commissioner IRCCourt RulingsJul 13, 2015related by meaning
an were part
of a split-dollar life insurance arrangement. We hold they were;
3Former secs. 6241-6245 generally required that the shareholders of an S corporation challenge the Commissioner's adjustments to an S corporation's
income in a single, corporate-level proceeding. However, the Small Business Job
Protection Act…
Notice 2014-35 — This notice provides administrative relief from the penalties under §§ 6652(d), 6652(e), and 6692 of the Code for a failure to timely comply with certain annua… IRCNoticesJun 2, 2014
…nitially adopted by DOL in 1995 and was updated in a published Federal Register notice on March 28, 2002 (67 FR 15052) (2002 DOL Notice). In order to encourage voluntary compliance with the ERISA annual reporting requirements by late filers, the DFVC Program allows plan administrators who fail to file a timely annual r…
Rev. Rul. 2014-18 — This ruling provides that a nonstatutory stock option or a stock appreciation right (each, a stock right) granted by a nonqualified entity for purposes of sect… IRCRevenue RulingsJun 23, 2014related by meaning
d restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations.
Rev. Proc. 2014–35 Rev. Proc. 2014–35 This revenue procedure provides safe harbors for applying the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members.
Not…
Rev. Proc. 2003-72 — EP determination letters; extension of application deadline for certain pre-approved plans. This procedure extends the deadline for filing EP determination let… IRCRevenue ProceduresSep 22, 2003
…01(b)-1(e)(3). .03 Generally, the GUST remedial amendment period ended on the later of February 28, 2002, or the last day of the first plan year beginning on or after January 1, 2001. However, Rev. Proc. 2000-20, 2000-1 C.B. 553, (as modified by Rev. Proc. 2000-27, 2000-1 C.B. 1272; Rev. Proc. 2001-55, 2001-2 C.B. 552;…
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 RulingsJan 21, 2020related by meaning
Judgment
Summary judgment is designed to expedite litigation and to avoid
unnecessary and expensive trials. Shiosaki v. Commissioner, 61 T.C. 861, 862 (1974). Under Rule 121(b), the Court may grant summary judgment when there is
no genuine dispute as to any material fact and a decision may be rendered as a
matter of la…
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
addition, the notice invites comments from the public regarding all aspects of these provisions.
ADMINISTRATIVE
Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
butions.
All section references are to the Internal Revenue Code of 1954, as amended and in effect during the years in issue, unless otherwise stated. Sec. 131(c), I.R.C. 1939; sec. 905(c), I.R.C. 1954.
8 The fact that the Board made specific findings of the rates of exchange in effect at the date of accrual and at the…
IRCPrivate Letter RulingsDec 1, 2006related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Third Party Communication: None
Date of Communication: Not Applicable
Number: 200648028
Release Date: 12/1/2006
Index (UIL) No.: 6166.00-00, 6403.00-00, 2055.00-00, 2511.02-00, 414 .00-00,
2053.09-00, 2032.00-00
CASE - MIS No.: TAM - 142156-05 AUGUST …
IRCPrivate Letter RulingsJan 17, 2003
…is directed only to City C and applies only
to the amended and restated Plan submitted on April 15, 2002 as revised by the
September 9, amendments and to the annuity contract submitted on May 17, 2002, as
revised by the amendments submitted on September 9, 2002. Section 6110(k)(3) of
the Internal Revenue Code provides …