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41. Notice 2007-67 — Section 906 of Pension Protection Act of 2006; Indian tribal governments; extension of transition relief. This notice extends the transition relief for plans o…
    IRCNoticesAug 27, 2007
    …additional transition issues need to be addressed. III. Extension of Transition Relief under Notice 2006-89 Since the issuance of Notice 2006-89, the Service and Treasury have continued to consult with Indian tribal government representatives. Based on those consultations and the comments received in response to Notice…
42. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    …is credibility. Therefore, we find that the -10Canadian property was not held for sale from October 2006 to October 2007 and was placed into service as a rental on October 7, 2006.6 Under section 1.168(i)-4(c), Income Tax Regs., when a property held for the production of income is converted to personal use, it is depre…
43. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    …ion. Mr. Couturier filed his income tax returns for the years at issue on April 11, 2005, April 15, 2006, April 15, 2007, October 9, 2008, and April 15, 2009, respectively. The Commissioner issued the Notice on
44. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    …justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the end of the matter; for the court, as well as the agency, must give effect to the unambiguously expressed intent of Congress.”).…
45. T.C. Memo. 2011-31 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsFeb 1, 2011
    …under section 72(t), and additions to tax for failure to file a return and failure to pay tax. III. 2006 Petitioner's 2006 Form 1040, which re'spondent received on April 19, 2007, reported zero wages, $79 of taxable interest, and $121 of taxable pension and annuity income. Petitioner claimed the standard deduction, a f…
46. Notice 2006-79 — This notice sets forth additional transition relief under section 409A. The notice generally extends through December 31, 2007, the transition relief that prev…
    IRCNoticesOct 23, 2006
    nly to amounts that would not otherwise be payable in 2006 and may not cause an amount to be paid in 2006 that would not otherwise be payable in 2006. With respect to an election or amendment to change a time and form of payment made on or after January 1, 2007 and on or before December 31, 2007, the election or amendm…
47. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011related by meaning
    …not necessarily disabled within the meaning of I section 72(m) (7). See Kopty v. Commissioner, T.C. Memo; 2007-343 (taxpayer who received long-term disability benefits from the U.S. Social Security Administration nct disabled within the' meaning of section 72(m) (7)), affd. 313 Fed. Appx. 333 (D.C. Cir. 2009); see also…
48. T.C. Memo. 2012-213 — Mark William Murray v. Commissioner
    IRCCourt RulingsJul 25, 2012
    …axpayers must file a return in order to elect to itemize deductions. See Jahn v. Commissioner, T.C. Memo. 2008-141, 2008 Tax Ct. Memo LEXIS 141, at *2, aff'd, 392 Fed. Appx. 949, 950 (3d Cir. 2010); Brunner v. Commissioner, T.C. Memo. 2004-187, 2004 Tax Ct. Memo LEXIS 193, at *10, aff'd, 142 Fed. Appx. 53 (3d Cir. 2005…
49. 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…
50. 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…
51. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017related by meaning
    … proceeded against the targets using information that the whistleblower provided after December 20, 2006. Id. at 403-404. Petitioner provided most of the information that he had available regarding the tax shelter scheme and its participants in April 2002. Viewing the alleged facts in a manner most favorable to petitio…
52. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010related by meaning
    a reasonable .dispute with respect to any item of income reported on an information return filed with the Secretary by a third party :and the taxpayer has "fully cooperated with the Secretary (including providing,,-, within ,a reasonable period-of time, access to and inspection of, all witnesses, information, and docum…
53. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983
    …ies); Moore v. Commissioner, 71 T.C. 533 (1979) (retail grocery store); Black v. Commissioner, T.C. Memo. 1983-245 (sales of developed real estate); Pilkington v. Commissioner, T.C. Memo. 1983-111 (operation of lounge); Smith v. Commissioner, T.C. Memo. 1983-93 (paint contracting business); Nelson v. Commissioner, T.C.…
54. 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)…
55. Treas. Reg. § 1.409(p)-1(b)(2)(iv)(C) — Prohibited allocation of securities in an S corporation.
    IRCRegulationsMay 18, 2016
    …ple.(i) Facts. Corporation M, an S corporation under section 1361, establishes Plan P as an ESOP in 2006, with a calendar plan year. Plan P is a qualified plan that includes terms providing that a prohibited allocation will not occur during a nonallocation year in accordance with section 409(p). On December 31, 2006, a…
56. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    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.…
57. Treas. Reg. § 1.436-1(j)(5)(iii)(D) — Limits on benefits and benefit accruals under single employer defined benefit plans.
    IRCRegulationsSep 9, 2016
    (j)(5)(iii)(D) (D) Special asset determinations for 2006 adjusted funding target attainment percentage —(1) General rule. If the adjusted funding target attainment percentage for the 2007 plan year is determined under the rules of paragraph (j)(5)(iii)(C) of this section, then the value of plan assets is determined as …
58. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
59. 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 …
60. 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…