IRCCourt RulingsNov 10, 1998related by meaning
tstanding rollover involved in
this case. Accordingly, the amount of excludable basis in the
instant case is computed by multiplying the amount of the distribution $6,100 by a fraction the numerator of which is
$1,950 and the denominator of which is $1,374.53 plus $6,100,
resulting in an amount excludable of $1,591.40.…
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsOct 19, 2010related by meaning
ense that it caused.to surface a
meritorious section 72(t) issue and resulted in respondent's
I
"Respondent's concession is presumably based upon sec. 72(t) (2) (A) (iv), which provides that the 10-percent additional
tax does not apply to distributions which are "part of a series
of substantially equal periodic payment…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
PLR 200005001 — Tax on Reversion of Qualified Plan Assets to Employer IRCPrivate Letter RulingsFeb 4, 2000related by meaning
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
October 13, 1999
Number: 200005001
Release Date: 2/4/2000
GL-609651-97/CC:EBEO:7
UIL: 4980.00-00
MEMORANDUM FOR DELAWARE - MARYLAND DISTRICT COUNSEL’S OFFICE
Attn: Sandra Jefferson
FROM: Michael Roach
Chief, Branch 7 CC:EBEO:7
SUBJECT:
- PROPOSE…
IRCCourt RulingsAug 6, 1997related by meaning
Motion for a Section 6673 Penalty
Respondent submitted a motion for the imposition of a
penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an
amount not to exceed $25,000 whenever it appears that the
taxpayer's position in a proceeding is frivolous,…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
Notice 2011-2 — This notice provides guidance on the application of section 162(m)(6) of the Code. Section 162(m)(6) limits the allowable deduction for remuneration for servic… IRCNoticesJan 10, 2011related by meaning
axable year to which deferred deduction remuneration is attributable in the case of a corporate event such as a merger, acquisition or reorganization. Comments may be submitted through March 23, 2011 to Internal Revenue Service, CC:PA:LPD:RU (Notice 2011-02), Room 5203, PO Box 7604, Ben Franklin Station, Washington DC …
IRCCourt RulingsApr 11, 2012related by meaning
nt and
other official explanations of such treaties; court cases; congressional
intent as reflected in committee reports, joint explanatory statements of managers included in conference committee reports, and floor
statements made prior to enactment by one of a lhill's managers;
General Explanations of tax legislation …
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
PBGCRegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsJan 27, 1998related by meaning
e excise tax notwithstanding that
they may have acted innocently or in good faith. Rutland v.
Commissioner
, 89 T.C. 1137, 1146 (1987). In signing the Agreement and Assignment of Accounts Receivable as a corporate
officer, petitioner, along with Mr. Cohen, implemented the
transfer of accounts receivable to the Plan. In…
PBGCRegulationsJul 1, 2019related by meaning
[Reserved]
81 FR 84458 — Extension of Import Restrictions Imposed on Certain Archaeological and Ethnological Material From Greece IRCFinal Rules (FR)Nov 23, 2016related by meaning
ntine culture (approximately the 4th century through the 15th century A.D.). On December 1, 2011, CBP published CBP Dec. 11-25 in the
Federal Register (76 FR 74691), which amended 19 CFR 12.104g(a) to indicate the imposition of these restrictions and included a list designating the types of archaeological and ecclesias…
Notice 2005-1 — This notice provides general and transitional guidance relating to new section 409A of the Code, added as part of the American Jobs Creation Act of 2004. Secti… IRCNoticesJan 10, 2005related by meaning
with Respect to Taxes on Income signed at Washington, D.C., on October 2, 1996.
The text of the Agreement is as follows:
COMPETENT AUTHORITY AGREEMENT The competent authorities of the United States and Switzerland hereby enter into the following agreement (“the Agreement”) regarding the qualification of certain U.S. an…