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41. 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…
42. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    …ce. See, e.g., Katz v. Commissioner, 115 T.C. 329, 337-338 (2000); Williamson v. Commissioner, T.C. Memo. 2009-188, 98 T.C.M. (CCH) 110, 112; Stockton v. Commissioner, T.C. Memo. 2009-186, 98 T.C.M. (CCH) 103, 106. Indeed, the regulations explicitly provide a taxpayer will not be granted a face-toface hearing when his …
43. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    ). VIII. Conclusion Petitioners received railroad retirement and Social Security benefits from the RRB during each of the years in issue . Petitioners have failed to prove that respondent incorrectly determined the adjustments to petitioners’ income on the basis of amounts that were not reported in the information retu…
44. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    Treasury. This clarification was in the preamble to the December 2020 grant of PTE 2020-02, and the Department is now adding it to the operative text. Although the proposed broader recordkeeping condition is consistent with other exemptions, the Department understands commenters' concerns that broader access to the doc…
45. REG-113792-13 — These proposed regulations provide guidance on the tax credit available to certain small employers that offer health insurance coverage to their employees unde…
    IRCProposed Rules (FR)Proposed Sep 16, 2013
    …r) offers one or more QHPs to its employees through a SHOP Exchange. For taxable years beginning in 2010, 2011, 2012, and 2013, section 45R(g) provides that the credit is determined without regard to whether the taxable year is in a credit period, and no credit period is treated as beginning with a taxable year beginni…
46. 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
    ed do not apply to requests for any documents to the extent § 6104 applies. Statement identifying information to be deleted from public inspection .04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
47. T.C. Summary Opinion 2014-18 — Thomas Wesley Alexander & Sylvia Alexander v. Commissioner
    IRCCourt RulingsFeb 26, 2014related by meaning
    …nces of his or her transactions. Bezdjian v. Commissioner, 845 F.2d 217 (9th Cir. 1988), aff'g T.C. Memo. 1987-140; Carlton v. United States, 385 F.2d 238, 243 (5th Cir. 1967) (citing Commissioner v. Duberstein, 363 U.S. 278, 286 (1960)). What actually was done determines the tax treatment of a transaction. Weiss v. St…
48. Notice 2010-20 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesFeb 22, 2010
    ginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% February 2010 4.38 3.94 4.60 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…
49. Notice 2010-36 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesApr 26, 2010
    Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% April 2010 4.40 3.96 4.62 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…
50. PLR 201610023 — Taxability of Beneficiary of Employee's Trust (Time and Manner of Taxation)
    IRCPrivate Letter RulingsMar 4, 2016related by meaning
    TAX EXEMPT AND GOVERNMENT ENTITIES DIVISION DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 DEC 07 2015 Uniform Issue List: 402.00-00 Legend: Taxpayer A = Plan B = Company C = Bank D = BankE = Account F = Amount 1 = Dear 201610023 This letter is in response to a request for a letter ruling, d…
51. Notice 2010-40 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesMay 24, 2010
    rs Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% May 2010 4.40 3.96 4.62 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…
52. Notice 2010-47 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesJun 28, 2010
    … Years Beginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% June 2010 4.39 3.95 4.61 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-mon…
53. Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi…
    IRCRevenue RulingsJul 17, 2006related by meaning
    hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan. ADMINISTRATIVE Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
54. Notice 2010-70 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesNov 1, 2010
    eginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% October 2010 4.28 3.85 4.49 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…
55. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025related by meaning
    …nce by taxpayers with the tax laws.”) ; IRM 5.8.11.3.3(1) ; see also Bergevin v. Commissioner, T.C. Memo. 2008-6, 2008 W L 123931, at *9. Factors supporting (but not conclusive of) a determination that compromise would undermine compliance include, but are not limited to, whether a taxpayer has taken deliberate action …
56. Notice 2010-76 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesNov 22, 2010
    ginning in 30-Year Treasury Weighted Average Permissible Range Month Year 90% to 105% November 2010 4.26 3.83 4.47 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…
57. Notice 2015-39 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2015 used under § 417(e)(3)(D), the 24-m…
    IRCNoticesJun 1, 2015related by meaning
    ictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations. EMPLOYEE PLANS Notice 2015–39 Notice 2015–39 This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2015 used under § 417(e)(3)(D), the 24-month avera…
58. T.C. Summary Opinion 2012-74 — Charles Grant & Elizabeth A. Beech v. Commissioner
    IRCCourt RulingsJul 26, 2012related by meaning
    …payers from strict compliance with procedural regulatory requirements". Dirks v. Commissioner, T.C. Memo. 2004-138 (citing Estate of Chamberlain v. Commissioner, T.C. Memo. 1999-181 (and cases cited therein), aff'd, 9 Fed. Appx. 713 (9th Cir: 2001)), aff'd, 154 Fed. Appx. 614 (9th Cir. 2005). Although the Court of Appe…
59. 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…
60. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsMar 3, 2000related by meaning
    …C:EBEO:4 TL-N-4712-99 UILC: 419.00-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR FROM: Assistant Chief Counsel (Employee Benefits and Exempt Organizations) CC: EBEO SUBJECT: This Field Service Advice is in res ponse to your memorandum dated October 5, 1999. Field Service Advice is not …