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21. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    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.
22. 85 FR 55587 — Lump Sum Payment Assumptions
    PBGCFinal Rules (FR)Sep 9, 2020
    …able in appendix C. For purposes of this example, assume the final rule became effective in January 2020, and a practitioner needed to determine the March 2020 rates. A practitioner would first determine the 12-year rate for the second preceding month, January 2020. The January 2020 corporate bond yield curve is publis…
23. Notice 2026-27 — This notice specifies updated static mortality tables to be used for defined benefit pension plans under § 430(h)(3)(A) of the Code and section 303(h)(3)(A) of…
    IRCNoticesMay 18, 2026related by meaning
    ic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F…
24. Rev. Proc. 2024-4 — This document updates Rev. Proc. 2023-4, 2023-1 IRB 162, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the …
    IRCRevenue ProceduresSuperseded Jan 2, 2024
    …pproved plans submitted with respect to the third six-year remedial amendment cycle. (c) Rev. Proc. 2020-10, 2020-21 IRB 295, provides that the third six-year remedial amendment cycle for pre-approved defined benefit plans began on May 1, 2020, and the on-cycle submission period for providers to submit opinion letter a…
25. Notice 2024-82 — This notice sets forth the 2024 Required Amendments List (2024 RA List). The 2024 RA List applies to individually designed plans qualified under section 401(a)…
    IRCNoticesDec 23, 2024
    …d. Guidance for Coronavirus-Related Distributions from Retirement Plans Under the CARES Act (Notice 2020-50, 2020-28 IRB 35). Under section 2202 of the CARES Act, plans may provide for in-service coronavirus-related distributions. Notice 2020-50 provides guidance with respect to this optional provision. Guidance on Wai…
26. 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…
27. 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…
28. Notice 2020-14 — This notice sets forth the 2020 Cumulative List of Changes in Plan Qualification Requirements for Pre-Approved Defined Benefit Plans (2020 Cumulative List). Th…
    IRCNoticesMar 23, 2020
    EMPLOYEE PLANS Notice 2020-14, page 555. This notice sets forth the 2020 Cumulative List of Changes in Plan Qualification Requirements for Pre-Approved Defined Benefit Plans (2020 Cumulative List). The 2020 Cumulative List sets forth specific matters the IRS has identified for review in determining whether a defined b…
29. Notice 2020-11 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for February 2020 used under § 417(e)(3)(D), the…
    IRCNoticesMar 9, 2020
    … BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for February 2020 without adjustment for the 25-year average segment rate limits are as follows: 24-Month Average Segment Rates Without 25-Year Average Adjustment Applicable Month First Segment Second Segment Third Segment February 2…
30. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    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…
31. Notice 2020-27 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2020 used under § 417(e)(3)(D), the 24…
    IRCNoticesMay 4, 2020
    …ATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for April 2020 without adjustment for the 25-year average segment rate limits are as follows: 24-Month Average Segment Rates Without 25-Year Average Adjustment Applicable Month First Segment Second Segment Third Segment April 2020…
32. 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…
33. Notice 2020-37 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2020 used under § 417(e)(3)(D), the 24-m…
    IRCNoticesJun 1, 2020
    …ORATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for May 2020 without adjustment for the 25-year average segment rate limits are as follows: 24-Month Average Segment Rates Without 25-Year Average Adjustment Applicable Month First Segment Second Segment Third Segment May 2020 2…
34. 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…
35. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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. …
36. T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (…
    IRCTreasury DecisionsMar 7, 2005related by meaning
    Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified. EXEMPT ORGANIZATIONS T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
37. 89 FR 54284 — Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations
    IRCFinal Rules (FR)Jun 28, 2024related by meaning
    of losses and expense items, does not exceed $10 million in the taxable year, determined by treating all such extraordinary items as positive amounts. (ii) Applicability date. This paragraph (e)(3) applies to partnership taxable years ending after December 29, 2022. For partnership taxable years ending before December …
38. Notice 2022-33 — Notice 2022-33 extends the deadlines for amending a retirement plan or IRA to reflect the provisions of Division O of the Further Consolidated Appropriations A…
    IRCNoticesAug 22, 2022
    …t (IRA) to reflect certain provisions of Division O of the Further Consolidated Appropriations Act, 2020, Pub. L. 116-94, 133 Stat. 2534 (2019), known as the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act), and section 104 of Division M of the Further Consolidated Appropriations Act, 2020…
39. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    Motion. Therefore, there is no need to opine on the potential broader implications of section 6501( l )(4). As the Chief Justice (then a judge on the D.C. Circuit) has observed, where “a sufficient ground [exists] for deciding [a] case, . . . the cardinal principle of judicial restraint — if it is not necessary to dec…
40. Notice 2022-45 — Notice 2022-45 extends the deadlines for amending an eligible retirement plan (including an individual retirement arrangement or annuity contract) to reflect t…
    IRCNoticesOct 17, 2022
    …CKGROUND A. Section 2202 of the CARES Act Under section 2202 of the CARES Act, enacted on March 27, 2020, and modified by section 280 of the COVID-related Tax Relief Act of 2020,2 qualified individuals receive favorable tax treatment with respect to coronavirus-related distributions from eligible retirement plans (as d…