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Go to T.C. Memo. 2007-163 (not yet in the library — opens the official source)
78 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. Rev. Proc. 2008-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section…
    IRCRevenue ProceduresSuperseded Jan 7, 2008
    …EEN MADE TO THIS PROCEDURE? In general .01 This revenue procedure is a general update of Rev. Proc. 2007-6, 2007-1 I.R.B 189, which contains the Service’s general procedures for employee plans determination letter requests. Other changes .02 In addition to minor revisions, such as updating references, the following cha…
  2. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025related by meaning
    Treas. Reg. § 1.482-7T(i)(6) does not operate as a safe harbor and therefore does not preclude R from making a PCT allocation under paragraph (i)(3). 6. Held, further, R did not abuse his discretion under I.R.C. § 482 by adjusting P’s and S’s RAB shares to determine the required CST p ayment. 7. Held, further, R ’s me…
  3. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    …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 depreciable only for …
  4. Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona…
    IRCNoticesModified Dec 22, 2008
    …uirements of §1.409A-1(c) should be adopted. See § XI of this notice. II. BACKGROUND On December 3, 2007, the Treasury Department and the IRS issued Notice 2007-100, 2007-52 I.R.B. 1243, setting forth guidance permitting the correction of certain operational failures, and providing transition relief limiting the amount…
  5. 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…
  6. REG-148326-05 — Proposed regulations address the calculation of amounts includible in income under section 409A(a) of the Code and the additional taxes imposed by such section…
    IRCProposed Rules (FR)Proposed Dec 22, 2008
    …n 409A, and providing transition guidance in accordance with the terms of the statute. On April 10, 2007, the Treasury Department and the IRS issued final regulations under section 409A. (T.D. 9321, 2007-19 I.R.B. 1123 [72 FR 19234], April 17, 2007). The final regulations are applicable for taxable years beginning afte…
  7. 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 …
  8. 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…
  9. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    …er 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
  10. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related 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…
  11. 76 FR 66136 — Investment Advice-Participants and Beneficiaries
    ERISAFinal Rules (FR)Oct 25, 2011
    …., Profit Sharing/401(k) Council of America, 50th Annual Survey of Profit Sharing and 401(k) Plans (2007); and Julie Agnew, Personalized Retirement Advice and Managed Accounts: Who Uses Them and How Does Advice Affect Behavior in 401(k) Plans?, Center for Retirement Research Working Paper 2006-9 (2006). Back to Citatio…
  12. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    …stituted a modification of the terms of the notes. We have previously noted that a technical advice memorandum is merely a ruling given to a specific taxpayer based upon the taxpayer's specific facts and is not a ruling of general application. See Golden Belt Tel. Association, Inc. v. Commissioner , 108 T.C. 498, 506 (…
  13. Notice 2007-100 — This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 4…
    IRCNoticesObsolete Dec 26, 2007
    …red compensation under the plan been properly deferred. The adjustment must be made by December 31, 2007, except that the adjustment can be made later, retroactively as of that date, if it is impracticable to make the adjustment by December 31, 2007 and the service recipient has a legally binding right on that date to …
  14. Notice 2009-86 — Further extension of effective date of normal retirement age regulations for governmental plans. This notice announces the intent to further extend the final e…
    IRCNoticesNov 16, 2009related by meaning
    ental plan or modify the relief previously provided in Notice 2007-69, 2007-2 C.B. 468. EXEMPT ORGANIZATIONS Announcement 2009-80 Announcement 2009-80 The Service has revoked its determination that Elimidebt Management Systems, Inc., of Orlando, FL and Hallandale, FL; and Richard & Jane Pater Charitable Foundation of S…
  15. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    ities. Classification of the transaction as a prohibited transaction under section 408(e) (2) (A) results in a deemed distribution of the IRA's assets to the taxpayer that is included in the taxpayer's income and is subject to a 10-percent additional tax. See secs. 72(t), 408(e) (2) (]B). In cases where the Service att…
  16. 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…
  17. Notice 2009-22 — Asset valuation under section 430(g)(3)(B) as amended by WRERA. This notice provides interim rules regarding asset valuation methods that are permitted to be u…
    IRCNoticesApr 6, 2009
    r than the actuary’s best estimate of the anticipated rate of return on plan assets for 2007, the assumed rate of return for 2007 is limited to 6.09%. For 2008, the third segment rate used to limit the assumed rate of return is the rate used for the January 1, 2008 valuation. Because the plan sponsor has elected to use…
  18. T.C. Memo. 2012-213 — Mark William Murray v. Commissioner
    IRCCourt RulingsJul 25, 2012related by meaning
    …ed annual payment for 2006 was 90% of the tax for that year. See id.; Missall v. Commissioner, T.C. Memo. 2008-258, 2008 Tax Ct. Memo LEXIS 254, at *7-8. Respondent has met his burden of production for the section 6654 addition to tax. The "section 6654 addition to tax is mandatory unless the taxpayer establishes that …
  19. 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…
  20. Rev. Proc. 2008-62 — This document sets forth the procedure by which the sponsor of a defined benefit plan, other than a multiemployer plan, may request and obtain approval for the…
    IRCRevenue ProceduresOct 20, 2008
    Rev. Proc. 2008-62 SECTION 1. PURPOSE AND CHANGES FROM REV. PROC. 2007-37 .01 The purpose of this revenue procedure is to set forth the procedure by which the sponsor of a defined benefit plan, other than a multiemployer plan, may request and obtain approval for the use of plan-specific substitute mortality tables in a…