IRCCourt RulingsMay 5, 2008
erseded by Rev .
Proc . 2003-61, 2003-2 C .B . 296, which is effective as to requests
for relief filed on or after Nov . 1, 2003, and for requests for relief pending on Nov . 1, 2003, as to which no preliminary
determination letter had been issued as of that date
. Although
petitioner's application for relief was filed…
IRCCourt RulingsFeb 28, 2024related by meaning
… contributions”
reportable on Form 5329.
5 On August 27, 2021, petitioner filed a second Motion for Summary Judgment, contending that the IRS “is precluded as a matter of
law from asserting excise tax liability under section 4973” because it did
not issue him a notice of deficiency challenging his income tax treatment
…
Rev. Rul. 2003-124 — Covered compensation tables; 2004. The covered compensation tables under section 401 of the Code for the year 2004 are provided for use in determining contribu… IRCRevenue RulingsDec 8, 2003
…g contributions to defined benefit plans and permitted disparity.
EXEMPT ORGANIZATIONS Announcement 2003-77 Announcement 2003-77
A list is provided of organizations now classified as private foundations.
ADMINISTRATIVE
Notice 2003-76 Notice 2003-76
This notice sets out transactions that have been identified by the Trea…
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…
IRCRegulationsSep 17, 2024
… introductory text of this section: Example.(i) A participant receives a $20,000 loan on January 1, 2003, to be repaid in 20 quarterly installments of $1,245 each. On December 31, 2003, the outstanding loan balance ($19,179) is deemed distributed as a result of a failure to make quarterly installment payments that were…
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…
IRCCourt RulingsJan 29, 2019related by meaning
made by the parties and, to the
extent they are not addressed herein, we find them to be moot, irrelevant, or
without merit.
To reflect the foregoing, Decision will be entered under
Rule 155.
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
…(W-t-W) tax credit. This document sets forth the conclusions of the IRS study relating to Rev. Rul. 2003-112 and announces that no credit will be allowed by the Service for any WOTC and W-t-W tax credit claims without proper certification by a designated local agency in accordance with the statute.
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 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…
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 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 RulingsMay 22, 2008
tax return relating to
2001 . In 2003, respondent prepared a substitute for return (SFR)
relating to petitioner's 2001 taxable year . On September 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 t…
Rev. Proc. 2006-3 — 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, 2006
…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. 1036; Rev. Proc. 2002-37, 2002-1 C.B. 1030 (certain corporations), as clarified and modified by Notice 2002-72 and modified by Rev. Proc. 2003-34; Rev. Proc. …
IRCCourt RulingsFeb 7, 2013related by meaning
ner, the taxpayer must demonstrate that the Commissioner's deficiency
assessment lacks a rational foundation or is arbitrary and excessive. Tinsman v. Commissioner, T.C. Memo. 2000-55.
- 8 -
Section 61(a) includes in gross income all income from whatever source
derived, including, but not limited to, interest. Sec. 61(…
IRCRegulationsDec 30, 2016
…. Plan A is amended to reduce significantly the rate of future benefit accrual effective January 1, 2003. Section 204(h) notice is required to be provided 45 days before January 1, 2003. Timely section 204(h) notice is provided to all applicable individuals (and to each employee organization representing participants w…
IRCCourt RulingsMar 14, 2019related by meaning
appears on dozens of other documents in the record. In any event petitioner offered no plausible explanation about
where the money went if not to him. 4We do not believe that respondent was obligated to concede the inapplicability of the section 72(t) additional tax or the nontaxability of $737 in miscellaneous income.…
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
…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. 1036; Rev. Proc. 2002-37, 2002-1 C.B. 1030 (certain corporations), as clarified and modified by Notice 2002-72 and modified by Rev. Proc. 2003-34; Rev. Proc. …
IRCCourt RulingsJul 24, 2017
…y installments due at the end of each
month. After making all monthly payments due through July 31,
2003, the participant fails to make the payment due on August 31,
2003 or any other monthly payments due thereafter. The plan
administrator allows a threemonth [sic] cure period.
(ii) As a result of the failure to satisf…
81 FR 40548 — Deferred Compensation Plans of State and Local Governments and Tax-Exempt Entities IRCProposed Rules (FR)Proposed Jun 22, 2016
…gical description of the relevant changes made after the 2003 final regulations were issued. (For a summary of the proposed changes to the 2003 final regulations, see the Explanation of Provisions section of this preamble.)