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Go to T.C. Memo. 2005-36 (not yet in the library — opens the official source)
66 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.D. 9072 — Final regulations under section 414(v) of the Code provide guidance on the requirements for retirement plans providing for catch-up contributions to individual…
    IRCTreasury DecisionsSep 15, 2003
    …plan year that is not the calendar year. For example, in a plan with a plan year ending on June 30, 2005, elective deferrals in excess of the employer-provided limit or the ADP limit for the plan year ending June 30, 2005, would be treated as catch-up contributions as of the last day of the plan year, up to the catch-u…
  2. T.C. Memo. 2009-187 — Eugene & Glenda Dollander v. Commissioner
    IRCCourt RulingsAug 19, 2009related by meaning
    …al hardship is not one of the exceptions in section 72(t)(2) . See Milner v . Commissioner , T .C . Memo . 2004-111 (no "umbrella hardship exception") ; Gallagher v . Commissioner , T .C . Memo . 2001-34 ("There is, however, no hardship exception in the controlling statutes .") . . . .continued) (A) the Thrift Savings …
  3. Treas. Reg. § 1.409(p)-1T(h) — Prohibited allocations of securities in an S corporation (temporary).
    IRCRegulationsMay 18, 2016
    icequity shares on determination date January 1, 2005 A grant is made on January 1, 2005 with a present value of $1,000. An additional grant of nonqualified deferred compensation with a present value of $775 is made on March 1, 2005 $10 per share 100 100 January 1, 2006 An additional grant is made on December 31, 2005 …
  4. T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (…
    IRCTreasury DecisionsMar 7, 2005
    Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified. EXEMPT ORGANIZATIONS T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
  5. Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th…
    IRCRevenue ProceduresJan 3, 2006
    … the group use a 52-53 week taxable year). SECTION 7. EFFECT ON OTHER REVENUE PROCEDURES Rev. Proc. 2005-3, 2005-1 C.B. 118, Rev. Proc. 2005-61, 2005-37 I.R.B. 507, and Rev. Proc. 2005-68, 2005-41 I.R.B. 694, are superseded. SECTION 8. EFFECTIVE DATE This revenue procedure is effective January 3, 2006. SECTION 9. PAPER…
  6. 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…
  7. Rev. Proc. 2006-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section…
    IRCRevenue ProceduresSuperseded Jan 3, 2006
    or subsequent years, in accordance with the rules set forth in Rev. Proc. 2005-66. Other Guidance .03 Other guidance affecting this revenue procedure: Rev. Proc. 2005-16, 2005-10 I.R.B. 674, describes the procedures for the “pre-approval” of plans under the master and prototype (M&P) program and the volume submitter (V…
  8. PLR 200118016 — Notification of Secretary of Labor
    IRCPrivate Letter RulingsMay 4, 2001related by meaning
    …30-00/CC:TEGE:EB:QP1 UILC: 4975.07-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area Attn: Laura Beth Heisen FROM: Michael Roach, Chief CC:TEGE:EB:QP1 SUBJECT: Adequacy of Department of Labor Notification Pursuant to I.R.C. §4975(h)…
  9. T.C. Memo. 2016-33 — Sally M. Costello v. Commissioner
    IRCCourt RulingsMar 1, 2016related by meaning
    ion provisions allow for the correction of an error made in a closed tax year by extending the limitations period up to one year from the date a - 8 - [*8] final determination is made. Secs. 1311, 1314(b); see Beaudry Motor Co. v. United States, 98 F.3d 1167, 1168 (9th Cir. 1996). Their intent is to take "the profit ou…
  10. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  11. T.C. Memo. 2011-83 — Bruce A. & Carol Anfinson Brown v. Commissioner
    IRCCourt RulingsApr 12, 2011
    to exceed the policy's cash value, and Northwestern terminated the policy on | January 6, 2005. On February 16, 2005, Northwestern restored the policy because Mr. Brown made a $559 "minimum interest payment" of which $428.04 went to interest and $130.96 went to principal. On March 21, 2005, Mr. Brown made a final cash …
  12. T.C. Memo. 2011-31 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsFeb 1, 2011
    … filing separately, and one exemption, and he sought a refund of $8,593. Petitioner attached to the 2005 Form 1040 a Form 4852 reflecting zero wages for 2005. Petitioner wrote "Non assumpsit by" above his signature on the jurats of the Form 1040 and Form 4852. Petitioner also attached a 67-page document entitled "Notic…
  13. 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…
  14. Treas. Reg. § 1.424-1(e)(7) — Definitions and special rules applicable to statutory options.
    IRCRegulationsJan 19, 2017
    2005, and on or before June 1, 2006. On June 1, 2004, the fair market value of X Corporation's stock is $100 per share. On February 1, 2005, X Corporation modifies the option to provide that the option shall be exercisable on or before September 1, 2006. On February 1, 2005, the fair market value of X Corporation stock…
  15. PLR 201927010 — Applicable Defined Benefit Plans
    IRCPrivate Letter RulingsJul 5, 2019
    …CSEC plan with respect to any given plan year, the plan must (1) have been in existence on July 26, 2005, (2) be a single plan mai ntained by more than one employer during the plan year that includes July 26, 2005 and each subsequent plan year through and including the plan year in question, and (3) satisfy the 85 perc…
  16. T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred…
    IRCTreasury DecisionsFeb 6, 2006related by meaning
    idance concerning the requirements for designated Roth contributions under qualified cash or deferred arrangements. EMPLOYMENT TAX T.D. 9239 T.D. 9239 Final, temporary, and proposed regulations under section 6011 of the Code relate to the time for employers to file returns and make deposits under the Federal Insurance …
  17. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    …me to verify, adequate substantiation for the matters in question. See Nguyen v. Commissioner, T.C. Memo. 2003-313 (and cases cited therein). Factual determinations were required to decide whether the distributions from NADA were taxable, whether the 10% additional tax applied, and whether petitioner was - 10 - entitle…
  18. PLR 200728042 — Additional Income and Taxes Generated from the Backdating or Discounting of Exercised Stock Options
    IRCPrivate Letter RulingsJul 13, 2007
    …fore January 1, 2008, the applicable guidance under §409A (including transition guidance) is Notice 2005-1, 2005-1 CB 274, the preamble to the Proposed Regulations under §409A, 2005-2 CB 786 (70 FR 57930), and Notice 2006-79, 2006-43 IRB 763. For taxable years beginning before January 1, 2007, the guidance provides tha…
  19. 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…
  20. Notice 2010-90 — This notice contains the 2010 Cumulative List of Changes in Plan Qualification Requirements (2010 Cumulative List) described in section 4 of Rev. Proc. 2007-44…
    IRCNoticesDec 27, 2010
    …(b)(3) of EGTRRA directed the Secretary of the Treasury to issue regulations under § 411(d)(6)(B). (2005 C. L.). Section 1.411(d)-3 of the Regulations was published on August 12, 2005 (70 Fed. Reg. 47109). (2005 C. L.). Amendments to § 1.411(d)-3 of the Final Regulations were published on August 9, 2006 (71 Fed. Reg. 4…