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Go to T.C. Memo. 1998-395 (not yet in the library — opens the official source)
68 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …
  2. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    …ble for the 10-percent additional tax imposed by section 72(t). See O'Connor v. Commissioner , T.C. Memo. 1994-170; Wheeler v. Commissioner , T.C. Memo. 1993-561; cf. Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissioner , T.C. Memo. 1995-93. III. Excise Tax Issues Finally, we turn to respondent's excise t…
  3. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
  4. T.C. Memo. 1996-450 — Theodore Souris, P.C., a dissolved corporation, and Theodore Souris, as successor in interest of Theodore Souris, P.C. v. Commissioner
    IRCCourt RulingsOct 2, 1996related by meaning
    g the term "employer reversion" subsection (c) begins with the words "For purposes of this section". Yet, as just indicated, both parties in this case treat the section 4980(c)(2) definition as applicable here for purposes of the income tax . Indeed this Court has so indicated. Lee Engineering Supply Co. v. Commissione…
  5. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    T.C. Memo. 1999-80 UNITED STATES TAX COURT EDWARD CLASBY AND C.T. GARRAHAN INSURANCE AGENCY, INC., Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1616-97. Filed March 16, 1999. Paul F. Markham , for petitioners. Mark L. Hulse and Gary W. Bornholdt , for respondent. MEMORANDUM FINDINGS OF FACT A…
  6. T.C. Memo. 1998-321 — Robert J. Hoaglund v. Commissioner
    IRCCourt RulingsSep 9, 1998
    T.C. Memo. 1998-321 UNITED STATES TAX COURT ROBERT J. HOAGLUND, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18418-97. Filed September 9, 1998. Robert J. Hoaglund, pro se. Margaret C. Tinagero , for respondent. MEMORANDUM OPINION JACOBS, Judge : This case is presently before the Court on respo…
  7. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
  8. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
  9. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  10. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004
    …on located in Atlanta, Georgia. Petitioner was the secretary/treasurer of Jocks and Jills, Inc., in 1998 and 1999, and its registered agent in Georgia in 1998 and 1999. On the dates shown supra in table 1 petitioner had a 33.165-percent interest in Jocks and Jills, Inc. There were more than 70 other partners; the next …
  11. T.C. Memo. 2009-263 — James A. & Linda A. Willhite v. Commissioner
    IRCCourt RulingsNov 18, 2009
    … the finalanalysis, petitioner[s] had no realistic choice ." Murillo v . Commissioner * * * [T .C . Memo . 1998-13 ., affd . without published opinion on other issues 166 F .3d 1201 (2d Cir . 1998)] ., citing Larotonda * * * [v . Commissioner , 89 T .C . 287 (1987)] . Petitioners did exactly what the law, and the IRS, …
  12. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    oner , T .C . Memo . 2004-125 . - 6 - Petitioner has not argued, and she has failed to demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right . Consequently, we must uphold TRHCA section 408 if it bears a rational relationship to a legitimate govern…
  13. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …), affd. without published opinion 578 F.2d 1383 (8th 042 Cir. 1978); Bartley v. Commissioner, T.C.·Memo. 1998-322; Ruben v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner, T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696; Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v. Commissione…
  14. T.C. Memo. 1999-161 — Roblene, Inc. v. Commissioner
    IRCCourt RulingsMay 13, 1999related by meaning
    does not include: - 17 - 8 The Small Business Job Protection Act of 1996, Pub. L. 104188, sec. 1434(a), 110 Stat. 1807, added sec. 415(c)(3)(D) which includes certain deferrals in participant's compensation, effective for years beginning after Dec. 31, 1997. This amendment does not apply to the instant case. We note, …
  15. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    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…
  16. T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a …
    IRCTreasury DecisionsMay 7, 2007related by meaning
    INCOME TAX Rev. Rul. 2007-29 Rev. Rul. 2007-29 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2007. Announcement 2007-44 Announcement 2007-44 This anno…
  17. IRCRegulationsMay 18, 2016
    … plan, the accrual rates for all HCEs (determined under the general test of § 1.401(a)(4)-3(c)) for 1998 are less than 1.5 percent of average annual compensation, and the accrual rates for all NHCEs (determined under the general test of § 1.401(a)(4)-3(c)) for 1998 are two percent of average annual compensation. If Emp…
  18. T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover …
    IRCTreasury DecisionsMar 23, 2009related by meaning
    on 414(w) for the entire plan year (or the portion of the plan year that the eligible NHCEs and eligible HCEs are eligible employees under the plan)). Qualified nonelective contributions and qualified matching contributions taken into account under §1.401(k)-2(a)(6) of this Chapter or qualified nonelective contribution…
  19. 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…
  20. PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsApr 23, 1999
    …g = Stock Holding 2 = State A = State B = Year 1 = This letter is in reply to a letter dated May 8, 1998, and supplemental correspondence, regarding the federal income tax consequences of a proposed transaction. Specifically, a ruling is requested that the conversion of a mutual insurance company to a stock insurance c…