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Go to T.C. Summary Op. 2012-74 (not yet in the library — opens the official source)
81 documents · 0.31sAllIRCERISAPBGCJoint Board
  1. Notice 2012-43 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesJun 25, 2012
    s Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% June 2012 3.88 3.49 4.08 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…
  2. Notice 2012-47 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesJul 30, 2012
    s Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% July 2012 3.83 3.44 4.02 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…
  3. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  4. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    … we will give effect to these concessions and to respondent's agreement to abate the portion of the 2012 tax attributable to those amounts. We assume that further abatements may be required with respect to self-employment tax and for portions of the sections 6651 and 6654 additions to tax. - 17 - [*17] C. Abuse of Disc…
  5. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    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…
  6. T.C. Summary Opinion 2005-103 — Basman Ahmad & Khitam Amerneh v. Commissioner
    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 …
  7. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
  8. T.C. Memo. 2022-9 — Hoops, LP, Heisley Member, Inc, Tax Matters Partner v. Commissioner
    IRCCourt RulingsFeb 23, 2022
    .S. Return of Partnership Income, for its taxable year ending December 31, 2012 (original 2012 tax return), using the accrual method of accounting. On its original 2012 tax return, Hoops: (1) did not claim an ordinary deduction of $10,673,327 relating to the deferred compensation liability, (2) did not reduce its amoun…
  9. 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…
  10. DOL Office of Administrative Law Judges — USDOL, EBSA v. PLAN ADMINISTRATOR, HOME OF ECONOMY 401(K) PLAN, HOME OF ECONOMY, INC.
    ERISACourt RulingsJun 26, 2013
    …ile an IQPA report with its Form 5500 Annual Report for the 2007 and 2009 plan years. On August 27, 2012, HOE filed Answers to both penalties. On September 6, 2012, the Chief Judge issued Notices of Docketing for both cases and assigned case numbers 2012 - RIS - 00113 and 2012 - RIS - 00114 . On October 3, 2012, EBSA f…
  11. 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…
  12. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    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…
  13. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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 …
  14. Notice 2012-53 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesAug 27, 2012
    Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% August 2012 3.77 3.39 3.96 MINIMUM PRESENT VALUE SEGMENT RATES In general, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month average. For plan years beginning in 2008 through …
  15. T.C. Summary Opinion 2011-113 — Gail Marie Watson v. Commissioner
    IRCCourt RulingsSep 28, 2011related by meaning
    …situation. Only Congress can change the statute. Accordingly, we will grant respondent's motion for summary judgment. To reflect the foregoing, An appropriate order and decision will be entered. 2Petitioner states: "I don't understand all the laws of government but one thing I do understand and can't believe is that th…
  16. Notice 2012-55 — This notice provides guidance on the 25-year average segment rates that are applied to adjust the otherwise applicable 24-month average segment rates that are …
    IRCNoticesSep 4, 2012
    …eviously issued 24-month average segment rates without adjustment, and, for plan years beginning in 2012, the adjusted 24-month average segment rates taking into account the 90-110% corridor around the 25-year average segment rates: Table 1: Adjusted 24-Month Average Segment Rates 24-Month Average Segment Rates not Adj…
  17. PLR 201313027 — Taxability of Beneficiary of Employee's Trust (Time and Manner of Taxation)
    IRCPrivate Letter RulingsMar 29, 2013related by meaning
    - ID: Office: UILC: CCA_2012121308293246 -------------------------- 402.00-00, 1311.00-00 Number: 201313027 Release Date: 3/29/2013 From: --------------------- Sent: Thursday, December 13, 2012 8:29:34 AM To: -------------------- Cc: Subject: RE: CCA - -------- This email follows up on the email below. We have reviewed…
  18. 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…
  19. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  20. Notice 2008-85 — This notice provides updated static mortality tables to be used in applying the minimum funding requirements to single employer defined benefit pension plans t…
    IRCNoticesOct 20, 2008
    …00 0.400000 120 1.000000 1.000000 1.000000 1.000000 1.000000 1.000000 1.000000 Mortality tables for 2012 Valuation dates occurring during 2012 Distributions subject to § 417(e)(3) with annuity starting dates during stability periods beginning in 2012 MALE MALE MALE FEMALE FEMALE FEMALE UNISEX Age 2012 Non-Annuitant Tab…