Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to T.C. Memo. 2004-138 (not yet in the library — opens the official source)
78 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
    IRCCourt RulingsAug 28, 2008related by meaning
    T .C . Memo . 2008-20 4 UNITED STATES TAX-COUR T WALTER KOWSH, Petitioner v . COMMISSIONER OF . INTERNAL . REVENUE, Responden t Docket No . 15154-06 . Filed August 28, 2008 . Walter Kowsh, pro se . Michelle L . Maniscalco , for respondent . MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N KROUPA, Judge : Respondent determined…
  2. Rev. Proc. 2004-15 — Minimum funding standards; waivers; notice. This procedure sets forth guidelines for requesting waivers of the minimum funding standards with respect to define…
    IRCRevenue ProceduresFeb 17, 2004
    …nces, preliminary conferences may be afforded in addition to conferences available under Rev. Proc. 2004-4, 2004-1 I.R.B. 125. SECTION 6. BANKRUPTCY PETITIONS If the applicant or a significant number of controlled group members file a bankruptcy petition after the request for a waiver of the minimum funding standard is…
  3. Ann. 2004-52 — Correction; section 457; Rev. Rul. 2004-57. A transition rule is set forth for a plan established before June 14, 2004, that does not satisfy the requirements …
    IRCAnnouncementsJun 14, 2004
    Announcement 2004-52 Correction Under Rev. Rul. 2004-57 Rev. Rul. 2004-57, page this Bulletin, provides that an eligible governmental plan under § 457(b) of the Internal Revenue Code must be established and maintained by an eligible employer as defined under § 457(e)(1)(A). A plan established before June 14, 2004, that…
  4. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    …he list of specific exceptions to tax set forth in section 72(t)(2). Swihart v. Commissioner , T.C. Memo. 1998-407. Moreover, unlike petitioners in the present case, the taxpayers in Larotonda never - 8 - received the funds and had no opportunity to avoid the 10-percent premature distribution penalty under former secti…
  5. Notice 2004-78 — Actuarial assumptions; distributions under section 101 of Pension Funding Equity Act of 2004. This notice provides guidance in question and answer format on th…
    IRCNoticesNov 29, 2004
    he plan year beginning in 2004 to an equivalent straight life annuity using 5.5% rather than the applicable interest rate of 5.25% as under prior law. In such a case, to satisfy the limitations of § 415 of the Code, the maximum single-sum distribution for a participant who is age 65 in 2004 would be $1,866,645 calculat…
  6. T.D. 9256 — Final regulations under section 417 of the Code concern content requirements applicable to explanations of qualified joint and survivor annuities and qualified…
    IRCTreasury DecisionsApr 17, 2006related by meaning
    SPECIAL ANNOUNCEMENT Announcement 2006-22 Announcement 2006-22 This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA program during calendar year 2005. This document does not provide guidance regarding the application of the arm’s length standa…
  7. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    on of the deficiencies, penalties, and additions to tax for 2004 and 2005. In his answering brief respondent concedes that petitioner is entitled to a deduction for an additional $15,800 in travel expenses previously disallowed for 2004. Respondent also concedes that petitioner is not liable for an enhanced accuracy-re…
  8. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    lated penalty with respect to all of its concessions listed in this paragraph. [*4] for the 2003, 2004, and 2005 tax years, including the pension plan contributions paid on behalf of Robert A. and Pearl Fletcher for the 2003 and 2004 tax years, (2) whether the compensation TORCH paid to the Fletchers' daughter, Grace-A…
  9. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …clude dismissal of this case and entry of * * * decision[s] against petitioner[s]." On December 20, 2004, respondent filed motions to impose sanctions on the grounds that petitioners had failed to comply with the Court's November 10, 2004, - 28 - [*28] orders, in that petitioners had not made available to respondent's …
  10. T.C. Memo. 2007-327 — Gregory Eugene Thompson v. Commissioner
    IRCCourt RulingsOct 31, 2007
    …ve on during 2005 . Petitioner requested a distribution from his retirement account in mid-November 2004 . The distribution did not take as long to process as anticipated . Petitioner received $ 62,467 .58 from his retirement account in December 2004 . PSRS withheld $12,493 .52 in Federal tax from the distribution . Pe…
  11. T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer …
    IRCTreasury DecisionsMay 23, 2016related by meaning
    ple, Deputy Commissioner for Services and Enforcement. Approved: April 29, 2016. Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy). Note (Filed by the Office of the Federal Register on May 3, 2016, 4:15 p.m., and published in the issue of the Federal Register for May 5, 2016, 81 F.R. 27011) [1] Section 20…
  12. 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’ …
  13. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
  14. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
  15. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    motion for costs was filed out of time and should be "dismissed" for that reason. We reject respondent's contention and do not consider it further. 12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is generally applicable to proceedings commenced after …
  16. Treas. Reg. § 1.422-4(d) — $100,000 limitation for incentive stock options.
    IRCRegulationsSep 9, 2016
    … using the fair market value of stock as of the date on the option is granted. During calendar year 2004, the aggregate fair market value of stock with respect to which E's options are exercisable for the first time exceeds $100,000. Therefore, the option for Y Corporation stock is treated as an incentive stock option,…
  17. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…
  18. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    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 …
  19. 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…
  20. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011related by meaning
    efore the loan was not a taxable distribution in 2003. On March 21, 2006, the Air Force removed petitioner from service and 'notified the TSP. The Air Force did not reinstate petitioner within 31 days from March 21, 2006. As a result, the TSP notified petitioner that the loan provisions required repayment of the outsta…