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41. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    …d and balanced decision, the Court will not reweigh the equities. Id.; Lipson v. Commissioner, T.C. Memo. 2012-252, at *9 (citing Fib Below Sales & Mktg., Inc. v. United States, 497 F.3d 828, 830 (8th Cir. 2007)). IRM pt. 5.14.1.4(4) (June 1, 2010) states: "Installment agreements must reflect taxpayers' ability to pay …
42. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    United States Tax Court T.C. Memo. 2024-6 CLAIR R. COUTURIER, JR. , Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent ————— Docket N o. 19714-16. Filed January 17, 2024. ————— Michael Eddison Romero , Alvah Lavar Taylor, Daniel W. Soto , and Jonathan T. Amitrano , for petitioner. Hilary E. March , Laura A. Pr…
43. Notice 2011-96 — This notice provides a sample plan amendment that plan sponsors may adopt to satisfy section 436 of the Code regarding limitations on the accrual and payment o…
    IRCNoticesModified Dec 27, 2011
    …), (h)(2), and (i) were published in the Federal Register on December 31, 2007, 72 FR 74215. Notice 2008-21, 2008-1 C.B. 431, provides that when the proposed regulations under §§ 430 and 436 are finalized, the final regulations will not apply to plan years beginning before January 1, 2009. Notice 2008-21 further provid…
44. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    performed by anyone else. Discussion Petitioners bear the burden of establishing that respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a); Welch v. Helvering , 290 U.S. 111 (1933). Petitioners' briefs refer to several facts which were not included…
45. 78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
    IRCFinal Rules (FR)Sep 19, 2013related by meaning
    nsions of the taxpayer's Federal tax return for the applicable taxable year, notwithstanding that the taxpayer may not have extended the due date. (3) Optional application of TD 9564. A taxpayer may choose to apply § 1.263(a)-1T as contained in TD 9564 (76 FR 81060) December 27, 2011, to taxable years beginning on or a…
46. Rev. Proc. 2009-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section…
    IRCRevenue ProceduresSuperseded Jan 5, 2009
    …EEN MADE TO THIS PROCEDURE? In general .01 This revenue procedure is a general update of Rev. Proc. 2008-6, 2008-1 I.R.B 192, 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…
47. Rev. Rul. 2008-7 — Accrued benefits; cash balance defined benefit pension plans; section 411 of the Code. This ruling, which pertains to a traditional defined benefit pension pla…
    IRCRevenue RulingsFeb 19, 2008
    EMPLOYEE PLANS Rev. Rul. 2008-7 Rev. Rul. 2008-7 Accrued benefits; cash balance defined benefit pension plans; section 411 of the Code. This ruling, which pertains to a traditional defined benefit pension plan that is amended in 2001 for the 2002 plan year into a cash balance defined benefit pension plan containing an …
48. 76 FR 13304 — Benefits Payable in Terminated Single-Employer Plans; Limitations on Guaranteed Benefits
    PBGCProposed Rules (FR)Proposed Mar 11, 2011
    June 1, 2008, the Company issues a notice pursuant to the Worker Adjustment and Retraining Notification (“WARN”) Act, 29 U.S.C. section 2101, et seq., that Facility A will close, and all employees will be permanently laid off, on or about August 1, 2008. The Company and the Union representing the employees enter into c…
49. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    Internal Revenue Code . Accordingly, petitioner is liable for the section 6662 penalty . In 2002, petitioner received distributions from a retiremen t plan . Pursuant to section 72(t), a 10H-percent additional tax is i 6 - imposed upon such distributions unless the distributions meet the requirements of one of the exce…
50. T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer …
    IRCTreasury DecisionsMay 23, 2016related by meaning
    ple, Deputy Commissioner for Services and Enforcement. Approved: April 29, 2016. Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy). Note (Filed by the Office of the Federal Register on May 3, 2016, 4:15 p.m., and published in the issue of the Federal Register for May 5, 2016, 81 F.R. 27011) [1] Section 20…
51. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010related by meaning
    …ent,inniaking See Green'v . Commissioner , 507 F .3d 857, 868' (5th Cir . 2007)' - : affg' . T .C . Memo . 2005-250 ;- 10 - Stocks v . Commissioner, 98 .T .C . 1,_ 9 4(1992) "[T]he critical question is, in lieu of what was the settlement amount paid"?, Bagley v . Commissioner , 105 T .C ._ 396, 406 (1995) . ., affd . -…
52. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
53. Notice 2008-24 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesFeb 25, 2008
    …ing target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from January 2008 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of January 2008 are, respectively, 4.39, 6.01, and 6.72. The three 24-month average corporate bond segment …
54. 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.…
55. Notice 2008-75 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesSep 22, 2008
    inning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% September 2008 4.72 4.24 4.95 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
56. Notice 2008-87 — This notice provides relief for funding deadlines and other requirements for plans in certain counties affected by Hurricane Ike. Relief is provided pursuant t…
    IRCNoticesOct 20, 2008
    …) or 303(j)(3) of ERISA for making a contribution falls within the period beginning on September 7, 2008, and ending on December 15, 2008, then the date for that contribution is postponed to December 15, 2008. If the date described in § 412(c)(5) of the Code and section 302(c)(5) of ERISA for applying for a waiver for …
57. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    moot, or irrelevant . To reflect the foregoing, Decision will be entere d for respondent . 8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the tax shown on the taxpayer's return for the year in question (or, if no return is filed, the taxpayer's tax…
58. Notice 2008-93 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesOct 27, 2008
    eginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% October 2008 4.70 4.23 4.93 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
59. Notice 2008-105 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesDec 1, 2008
    ginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% November 2008 4.68 4.21 4.91 MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
60. 89 FR 32346 — Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    nd in its text, PTE 2020-02 has been broadly amended to encompass compensation for advice irrespective of the product recommended. Back to Citation 6.  ERISA section 408(a) and Code section 4975(c)(2), expressly permit the Department (through the Reorganization Plan No. 4 of 1978) to grant “a conditional or uncondition…