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41. 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…
42. 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…
43. 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’ …
44. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
45. 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
    , or documents to which §6104 (document open to public inspection) applies, as described in section 10.03. Taxpayer may protest deletions not made .05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
46. 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…
47. 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…
48. 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 …
49. 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…
50. U.S. Tax Court — Susan Elizabeth Machlay v. Commissioner
    IRCCourt RulingsFeb 10, 2009related by meaning
    ic v . ,Commissioner , T .C . Memo . 1992-- 609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . . In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her medical condition . She explained at trial that although she received treatment from doctors in 2005, she did …
51. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
52. T.C. Memo. 2020-101 — Tamecca Seril a.k.a. Tamecca Tillard v. Commissioner
    IRCCourt RulingsJul 8, 2020related by meaning
    pplied to the IRS. On September 17, 2018, the AUR unit sent petitioner a Notice CP2000 indicating that she (1) had failed to report $15,000 of taxable distributions, (2) had underreported the 10% additional tax due, and (3) was subject to an accuracy-related penalty. The letter instructed her to file a response by Octo…
53. 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,…
54. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    v. Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo. 2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v. - 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001). While we acknowledge and are sympathetic to petitioner's financial straits, we have no aut…
55. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    stituting a 6-year period in lieu of the 3-year period otherwise referred to in such subsection. (D) Exception for certain acquisitions of property. — In the case of any tax imposed by section 4973 that is attributable to acquiring property for less than fair market value, subparagraph (A) shall not apply. Section 313(…
56. 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 …
57. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017related by meaning
    and after the effective date of section 7623(b). See Whistleblower 1133213W v. Commissioner, 142 T.C. 396. In that case we held that the determinative issue is whether the whistleblower alleged facts that, if proven, would establish that the Commissioner proceeded against the targets using information that the whistleb…
58. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8 (2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on the date which is 60 days after the later of . . . [the] earliest incident date . . …
59. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    … years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-277 UNITED STATES TAX COURT MARGARET M. MERKER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26855-95. Filed June 18, 1997. Margaret M. Merker, pro se. Marjory A. Gilbert , for respon…
60. T.C. Memo. 2003-223 — Richard Wos v. Commissioner
    IRCCourt RulingsJul 29, 2003related by meaning
    bmitted a document to the Court entitled “Trial Memorandum of Petitioner” that the Court had filed (petitioner’s trial memorandum). Petitioner’s trial memorandum contained various statements, contentions, and arguments with respect to what constitutes income for tax purposes that the Court found in an Order dated March…