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Go to T.C. Summary Op. 2003-77 (not yet in the library — opens the official source)
82 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. U.S. Tax Court — Andrea C. Casula v. Commissioner
    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…
  2. 75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac…
    IRCFinal Rules (FR)Jul 6, 2010related by meaning
    3. Section 301.6033-5 is added to read as follows: § 301.6033-5 Disclosure by tax-exempt entities that are parties to certain reportable transactions. (a) In general. For provisions relating to the requirement of the disclosure by a tax-exempt entity that it is a party to certain reportable transactions, see § 1.6033-5…
  3. 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…
  4. 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.
  5. Treas. Reg. § 1.72(p)-1(b) — Loans treated as distributions.
    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…
  6. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    cated, and all Rule references are to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining wheth…
  7. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016
    120, U.S. Corporation Income Tax Return (2003 corporate return), for 2003. Petitioners filed a joint Form 1040, U.S. Individual Income Tax Return, for 2003 (2003 joint return) before April 15, 2004. They reported that they had received IRA distributions totaling $432,076.41,5 that these distributions were the subject o…
  8. T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409…
    IRCTreasury DecisionsJan 18, 2005related by meaning
    INCOME TAX Rev. Rul. 2005-3 Rev. Rul. 2005-3 Section 901(j)(5) Presidential waiver; Libya. Pursuant to a section 901(j)(5) Presidential waiver, section 901(j)(1) of the Code ceased to apply to Libya effective December 10, 2004. Section 911(d)(8) is not applicable to Libya after September 20, 2004, and Iraq after July 2…
  9. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    …rences are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. We must decide whether petitioner's contribution to its trust created as part of its voluntary employees' beneficiary association (VEBA) plan for the 1986 taxable year is deductible. Specifically, we mu…
  10. 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…
  11. T.C. Memo. 2023-141 — Danielle Monique Scott v. Commissioner
    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…
  12. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    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…
  13. 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
    …adoption of good faith EGTRRA plan amendments.[4] .07 Rev. Proc. 2002-29, as modified by Rev. Proc. 2003-10, 2003-2 I.R.B. 259, provides that defined contribution plans must be amended to the extent necessary to comply with final and temporary regulations under § 401(a)(9). In general, these amendments must be adopted …
  14. T.D. 9324 — Final regulations under section 402A of the Code provide guidance concerning the taxation of distributions from designated Roth accounts under qualified cash o…
    IRCTreasury DecisionsMay 29, 2007related by meaning
    …-32 This procedure updates the Gaming Industry Tip Compliance Agreement (GITCA) Program, Rev. Proc. 2003-35, 2003-1 C.B. 919. This program allows gaming industry employers to work with the Service to create voluntary agreements establishing minimum tip rates for tipped employees in specified occupational categories. On…
  15. T.C. Summary Opinion 2005-62 — Thomas Richard & Donna Estes White v. Commissioner
    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.
  16. 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))…
  17. 80 FR 22021 — Proposed Amendment to and Proposed Partial Revocation of Prohibited Transaction Exemption (PTE) 86-128 for Securities Transactions Involving Employee Benefit P…
    ERISAProposed Rules (FR)Proposed Apr 20, 2015related by meaning
    s) earned in connection with the transactions covered by the exemption. Back to Citation 7.  67 FR 64137 (October 17, 2002). Back to Citation 8.   See Advisory Opinion 2011-08A (June 21, 2011). Back to Citation 9.  This proposal would move the definitions from Section I to Section VII. The other sections are re-ordered…
  18. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    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…
  19. T.C. Summary Opinion 2003-77 — Wallace W. Burke v. Commissioner
    IRCCourt RulingsJun 18, 2003related by meaning
    ly to assist taxpayers in filing tax returns; neither the Commissioner nor this Court is bound by such guidance where it is contrary to (continued...) taxpayer’s gross income generally are not part of the taxpayer’s investment in the contract, sec. 72(f). Therefore, in the context of this case, a taxpayer’s investment …
  20. Treas. Reg. § 54.4980F-1(c7)(3) — Notice requirements for certain pension plan amendments significantly reducing the rate of future benefit accrual.
    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…