IRCCourt RulingsOct 19, 2010related by meaning
… •
warnings that he was in danger of being penalized. For example,
in Mathews v. Commissioner, T.C. Memo. 2005-84, we told
petitioner:
"Even though the filing of the petition resulted in
respondent's concession of the sec. 72(t) additional tax,
IRCCourt RulingsNov 12, 1997
… total 1991 tax
- 8-8
liability to be $25,000, which was fully paid through withholdings.
In August 1992, petitioner filed Form 2688 (Application for Additional Extension of Time To File U.S. Individual Income Tax
Return) seeking an additional 2-month extension of the time to file
his 1991 tax return because he was sti…
ERISACourt RulingsFeb 2, 1993
14, 1992, certain
special procedural rules were prescribed for the presentation of
evidence and argument by the parties in written form. In accordance with those procedural rules, Respondent's opening statement dated
April 2, 1992, with attached Exhibits "A" through "I"; Pt/BA's
opening statement dated May 24, 1992, wi…
ERISACourt RulingsFeb 1, 1993
Respondent's statement of
reasonable cause, due January 13, 1992, that was filed subsequent
to January 13 if Respondent describes in the statement of reasonable cause what is intended to be produced and a reasonable
time frame within which to produce these items. This letter was
received on or about January 8, 1992.
1…
IRCCourt RulingsDec 29, 2008
…
641 (9th Cir . 2008) (quoting United States v . Plummer 174 Bankr .
284, 286 (Bankr . C .D . Cal . 1992)) .
Nonetheless, in reexamining the table supra page 5, we note
that even accepting respondent's application as given, petitioner
has paid more than her share of the liabilities for 1992 and
1995 . Further, if one w…
IRCPrivate Letter RulingsMar 3, 2000related by meaning
…C:EBEO:4
TL-N-4712-99
UILC: 419.00-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR
FROM: Assistant Chief Counsel (Employee Benefits and Exempt
Organizations) CC: EBEO
SUBJECT:
This Field Service Advice is in res ponse to your memorandum dated October 5,
1999. Field Service Advice is not …
ERISACourt RulingsMar 20, 1995
…e Department [of
Labor]."
The Respondent was also notified of the 45-day time limit in the April 3, 1992, letter of
rejection, which it received on April 7, 1992. Respondent sent in the requested additional
information by letter of May 21, 1992; 48 days after the date of the April
3, 1992, Notice, but only 44 days afte…
T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr… IRCTreasury DecisionsDec 9, 2013related by meaning
of safe harbor matching contributions for plan years beginning on or after January 1, 2015.
EMPLOYMENT TAX
T.D. 9646 T.D. 9646
REG–146620–13T.D. 9646 Temporary and proposed regulations under section 3402(p)(3) relating to voluntary withholding agreements allow the Secretary to issue guidance in the Internal Revenue Bu…
IRCCourt RulingsJan 26, 1998
…ts a finding
that the transactions did not create bona fide debt. Cf. Fuller
v. Commissioner
, T.C. Memo. 1980-370 (taxpayers submitted
evidence that their net worth substantially exceeded the sum of
- 15 -
the balances on the promissory notes, and thereby demonstrated
their ability to repay the obligation).
e. The Rel…
IRCFinal Rules (FR)Dec 18, 2024related by meaning
… the Treasury.
David Lebryk,
Fiscal Assistant Secretary.
Footnotes
1. Public Law 117-328 (Dec. 29, 2022), Division T; 31 U.S.C. 3105(f).
Back to Citation
2.
31 U.S.C. 3105(f)(1)(A).
Back to Citation
3.
31 U.S.C. 3105(f)(1)(C).
Back to Citation
4.
31 U.S.C. 3105(f)(6).
Back to Citation
5.
31 U.S.C. 3105(f)(2)(A).
B…
IRCCourt RulingsDec 19, 1995
…fer Refund does not constitute a qualified total
distribution. See Wittstadt v. Commissioner
, T.C. Memo. 1995492; Humberson v. Commissioner
, T.C. Memo. 1995-470; Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 ; Adler v. Commissioner
, T.C.
Memo. 1995-148; Dorsey v. Commissioner
, T.C. Memo. 1995-97; Brown
v. Commissi…
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014related by meaning
P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made.
When no copy is given to the taxpayer
.06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
IRCCourt RulingsJun 25, 2012related by meaning
other grounds, and
remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206;
Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 -
II. Administrative Costs
The administrative costs at issue are costs that petitioner incurred from the .
time respondent issued the notice of deficiency up to the …
IRCCourt RulingsSep 3, 1998related by meaning
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property IRCFinal Rules (FR)Sep 19, 2013related by meaning
2011, to taxable years beginning on or after January 1, 2012, and before January 1, 2014.
§ 1.1016-3T
[Removed]
Par. 32.
Section 1.1016-3T is removed. PART 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT
Par. 33.
The authority citation for part 602 continues to read as follows:
Authority:
26 U.S.C. 7805.
Par.…
IRCCourt RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…
IRCCourt RulingsJun 13, 2017related by meaning
JRN
T.C. Memo. 2017-112
UNITED STATES TAX COURT
WHISTLEBLOWER 19860-15W, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19860-15W. Filed June 13, 2017.
Sealed,¹ for petitioner.
Ashley M. Bender and Richard L. Hatfield, for respondent.
MEMORANDUM OPINION
KERRIGAN, Judge: This case is before the Co…
T.D. 9958 — This document sets forth temporary regulations implementing certain transparency requirements under section 204 of Division BB of Title II of the Consolidated … IRCTreasury DecisionsDec 6, 2021related by meaning
d: November 12, 2021.
_____________________________
Xavier Becerra
Secretary,
Department of Health and Human Services.
List of Subjects
5 CFR Part 890 Administrative practice and procedure, Government employees, Health facilities, Health insurance, Health professions, Hostages, Iraq, Kuwait, Lebanon, Military personnel…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
ent and the IRS will publish for public availability any comment submitted electronically or on paper to its public docket.
V. PAPERWORK REDUCTION ACT The collection of information contained in this notice has been submitted to the Office of Management and Budget in accordance with the Paperwork Reduction Act (PRA) (44…