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…
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…
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…
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…
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…
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
Rights II, the Internal Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004.
REG-111833-99 REG-111833-99 Proposed regulations under section 7430 of the Code relate to awards of administrative costs and attorneys fees to conform the regulations to the amendments made in the …
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…
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…
T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a … IRCTreasury DecisionsMay 7, 2007related by meaning
INCOME TAX
Rev. Rul. 2007-29 Rev. Rul. 2007-29
Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2007.
Announcement 2007-44 Announcement 2007-44
This anno…
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 …
IRCCourt RulingsSep 13, 2010related by meaning
… a matter which is within the discretion of the
Commissioner . . Colvin v . . Commissioner , T .C . Memo . 2004-67, affd .
122 Fed . Appx . 788 (5th Cir . 2005) .
Furthermore,petitioners have failed to identify a
ministerial or managerial delay by an IRS employee that cause d
,them to forgo making payments on their . i…
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 …
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 …
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…
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
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…
IRCCourt RulingsDec 13, 2012related by meaning
CLC
T.C. Memo. 2012-344
UNITED STATES TAX COURT
KARL E. CROSS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6009-09. Filed December 13, 2012.
Mitchell Stuart Fuerst and Joseph A. DiRuzzo III, for petitioner.
Brian E. Derdowski, Jr., and Carroll De Groff Lansdell, for respondent.
MEMORANDUM OPIN…
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 …
IRCCourt RulingsJul 6, 2022related by meaning
United States Tax Court
T.C. Memo. 2022-69
CLAIR R. COUT URIER, JR. ,
Petitioner
v .
COMMISSIONER OF INTERNAL REVENUE,
Respondent
—————
Docket N o. 19714-16. Filed July 6, 2022.
—————
Alvah Lavar Taylor and Daniel W. Soto , for petitioner.
Laura A. Price, Hilary E. March , Noelle White, Patricia P. Wang , and
Edward T.…
T.D. 9081 — REG-129709-03 Temporary and proposed regulations under section 409(p) of the Code provide guidance concerning the requirements for employee stock ownership pla… IRCTreasury DecisionsSep 2, 2003related by meaning
t rates used to calculate current liability for purposes of the full funding limitation of section 412(c)(7) of the Code are set forth.
ADMINISTRATIVE Notice 2003-59 Notice 2003-59
Uniform capitalization; methods of accounting. This notice modifies Notice 2003-36 to permit certain taxpayers to use the automatic approva…