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…
IRCCourt RulingsOct 12, 1978related by meaning
…a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comment letter, there are a few allegations which are prop…
Rev. Proc. 2014-8 — User fees for employee plans and exempt organizations. Current guidance for complying with the user fee program of the Service as it pertains to requests for l… IRCRevenue ProceduresJan 2, 2014
istrative scrutiny determination
Rev. Proc. 93–41
Adoption agreement
Rev. Procs. 2011–49, 2013–22
Advisory letter
Rev. Procs. 2011–49, 2013–22, 2014–6 Basic plan document
Rev. Procs. 2011–49, 2013–22
Determination letter
Rev. Procs. 2014–6, 2014–9
Dual-purpose IRA
Rev. Procs. 98–59, 2010–48
Group exemption letter
Rev. …
Notice 2013-32 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in May 2013; the 24-month average segment rates; th… IRCNoticesMay 28, 2013
… Patient Protection and Affordable Care Act (Public Law 111-148, 124 Stat. 119, 868 (2010)).
Notice 2013-32 Notice 2013-32
This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in May 2013; the 24-month average segment rates; the funding transitional segment rates a…
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.
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…
Notice 2013-52 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in August 2013; the 24-month average segment rates;… IRCNoticesAug 26, 2013
…unding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from July 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of July 2013 are, respectively, 1.34, 4.45, and 5.44. For plan years beginning on or after January 1, 2012,…
T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner IRCCourt RulingsAug 17, 2026
…assist in
our qualitative analysis.
34
Mr. Hewlett provided appreciation rates for select months in 2013 and 2014:
April 2013 at 19%; July 2013 at 14%; November 2013 at 6%; December 2013 at 4%;
March 2014 at 4%; and October 2014 at 1%. For the appreciation rates not expressly
provided by Mr. Hewlett, we have assumed co…
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 RulingsNov 30, 2006related by meaning
ted States
, 68 Fed. Cl.
177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States
,
supra
, at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy
, 516
U.S. 235, 252 (1996) (courts are “bound by the language of the
statute as it is written”); Badaracco v. …
Notice 2013-11 — 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 … IRCNoticesMar 11, 2013
ears beginning in 2013, the adjusted 24-month average segment rates taking into account the 85-115% corridor around the 25-year average segment rates: For Plan Years Beginning In 24-Month Average Segment Rates Not Adjusted Adjusted 24-Month Average Segment Rates, Based on Applicable Percentage of 25-Year Average Rates
…
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…
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 2013 Valuation dates occurring during 2013 Distributions subject to § 417(e)(3) with annuity starting dates during stability periods beginning in 2013
MALE MALE MALE FEMALE FEMALE FEMALE UNISEX
Age 2013 Non-Annuitant Tab…
Rev. Rul. 2013-2 — 2013 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2013 are provided for use in … IRCRevenue RulingsMar 4, 2013
INCOME TAX
Notice 2013-12 Notice 2013-12
This notice reports the results of the section 48C Phase I program and, as provided by section 48C(d)(4) of the Code, establishes a second phase of the qualifying advanced energy project program (“the section 48C Phase II program”) to distribute the section 48C Phase I credits t…
IRCCourt RulingsJan 17, 2024related by meaning
… additions to tax
and the penalties .
Currently before the Court is respondent’s Motion for Partial
Summary Judgment . H e seeks a ruling that section 4973 impo ses a
“ tax , ” not a “penalty” to which the provisions of section 6751 (b) c ould
appl y . We a gree with respondent and w ill accordingly grant his Motion.
B…
Notice 2013-28 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in April 2013; the 24-month average segment rates; … IRCNoticesMay 6, 2013
…nding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from March 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of March 2013 are, respectively, 0.97, 3.82, and 5.11. For plan years beginning on or after January 1, 2012…
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…
IRCCourt RulingsMay 19, 2011related by meaning
nd
to the extent not discussed herein we conclude that they are
irrelevant, moot, or without merit.
To reflect the foregoing,
Decision will be entered under Rule 155.
Notice 2013-37 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in June 2013; the 24-month average segment rates; t… IRCNoticesJun 24, 2013
…funding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from May 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of May 2013 are, respectively, 0.97, 3.76, and 5.01. For plan years beginning on or after January 1, 2012, …
IRCCourt RulingsApr 2, 2024related by meaning
is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8
(2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on
the date which is 60 days after the later of . . . [the] earliest incident date . . …