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.…
IRCCourt RulingsDec 18, 2012
s motion. Petitioners did
not file a joint report as required by the Court's February 18, 2010, order, and they
did not file a separate status report. On April 20, 2010, the Court granted respondent's April 15, 2010, motion and
ordered the parties to file a joint status report or to submit their stipulated decisions
by…
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…
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 RulingsAug 31, 2021related by meaning
… in so concluding. See Pough v.
Commissioner , 135 T.C. 344, 352 (2010).
Considering the foregoing, summary judgment for respondent is appropriate
in this matter .
We have considered all of the arguments that the parties made , and to the
extent they are not addressed herein, we consider them to be moot, irrelevant, or…
Notice 2010-52 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesJul 26, 2010
EMPLOYEE PLANS
Notice 2010-52 Notice 2010-52
Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in July 2010; the 24-month average segment rates; the fundin…
ERISADOL Technical ReleasesMar 18, 2011
partments published interim final regulations implementing PHS Act section 2719 on July 23, 2010, at 75 FR 43330 (the 2010 interim final regulations). On September 20, 2010, the Department of Labor issued Technical Release 2010-02 (T.R. 2010-02), which set forth an enforcement grace period for compliance with certain n…
IRCCourt RulingsJul 25, 2005related by meaning
settlement
agreement is not a qualified domestic order, and Mr. Ahmad is not
an alternate payee, the exception in section 72(t)(2)(C) is
inapplicable. In light of the foregoing, the Court holds that petitioners
are liable for the 10-percent additional tax imposed under
section 72(t).
Reviewed and adopted as the report …
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…
Notice 2013-84 — This notice contains the 2013 Cumulative List of Changes in Plan Qualification Requirements (2013 Cumulative List) described in section 4 of Rev. Proc. 2007–44… IRCNoticesDec 23, 2013
…to amend for § 401(a)(35) to the last day of the first plan year that begins on or after January 1, 2010. (2010 C. L.)
Final regulations under § 401(a)(35) were published on May 19, 2010. (2010 C. L.)
Notice 2013–17, 2013–20 I.R.B. 1082, provides relief from anti-cutback rules for an amendment to an ESOP to eliminate a…
T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b… IRCTreasury DecisionsDec 7, 2015
grandfathered health plan:
(A) Changes effective after March 23, 2010 pursuant to a legally binding contract entered into on or before March 23, 2010; (B) Changes effective after March 23, 2010 pursuant to a filing on or before March 23, 2010 with a State insurance department; or
(C) Changes effective after March 23, 2…
Notice 2010-57 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesAug 23, 2010
EMPLOYEE PLANS
Notice 2010-57 Notice 2010-57
Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in August 2010; the 24-month average segment rates; the fund…
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…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
B. 2026-01 143
2026-4 2026-01 I.R.B. 2026-01 160
2026-5 2026-01 I.R.B. 2026-01 258
2026-6 2026-02 I.R.B. 2026-02 314
2026-7 2026-02 I.R.B. 2026-02 316 2026-8 2026-04 I.R.B. 2026-04 380
2026-9 2026-04 I.R.B. 2026-04 393
2026-10 2026-04 I.R.B. 2026-04 394
2026-12 2026-07 I.R.B. 2026-07 535
2026-13 2026-09 I.R.B. 2026-09 …
IRCCourt RulingsSep 30, 2003related by meaning
t for payment of an assessed
deficiency and the bank trustee paid the money directly to the
IRS. Former section 72(m)(5) differed from current section 72(t), particularly in that the former did not include the list
of specific exceptions to tax set forth in section 72(t)(2).
Swihart v. Commissioner
, T.C. Memo. 1998-40…
IRCCourt RulingsSep 25, 2019related by meaning
…scribed any expenditure that would qualify for a
2013 deduction or credit. In opposing a motion for summary judgment, the
nonmovant may not rest upon the mere allegations or denials in his pleadings but
instead must set forth specific facts showing that there is a genuine dispute for
trial. Rule 121(d); see Sundstrand …
IRCCourt RulingsFeb 9, 2023related by meaning
s at issue in First Security Bank . Such a
determination would not inform our understanding of the holding or
reasoning of First Security Bank .
GG. T he Tax Reform Act of 1976
In 1976, Congress amended section 482 of the Internal Revenue
Code of 1954 to replace “the Secretary or his delegate” with “the
Secretary”. 26 …
REG-113792-13 — These proposed regulations provide guidance on the tax credit available to certain small employers that offer health insurance coverage to their employees unde… IRCProposed Rules (FR)Proposed Sep 16, 2013
…r) offers one or more QHPs to its employees through a SHOP Exchange. For taxable years beginning in 2010, 2011, 2012, and 2013, section 45R(g) provides that the credit is determined without regard to whether the taxable year is in a credit period, and no credit period is treated as beginning with a taxable year beginni…
Notice 2010-20 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesFeb 22, 2010
ginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
February 2010 4.38 3.94 4.60
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…
IRCCourt RulingsMay 9, 2002related by meaning
e underpayment which is attributable
to any substantial understatement of income tax. Sec.
6662(b)(2). A “substantial understatement” exists where the amount of the understatement exceeds the greater of 10 percent of
the tax required to be shown on the return for the taxable year
or $5,000. Sec. 6662(d)(1).
No penalty …