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Go to T.C. Memo. 2011-132 (not yet in the library — opens the official source)
76 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    nd to the extent not discussed herein we conclude that they are irrelevant, moot, or without merit. To reflect the foregoing, Decision will be entered under Rule 155.
  2. Notice 2011-3 — Special rules relating to funding relief for single-employer pension plans under PRA 2010. This notice provides guidance on the special rules relating to fundi…
    IRCNoticesJan 10, 2011
    the plan year beginning July 1, 2011, total $500,000, and that the adjusted net income for the fiscal year ending September 30, 2010, was $1,000,000. (b) If the dividends declared during the plan year beginning July 1, 2011, were determined in the same manner as those declared during the 60 months preceding July 1, 20…
  3. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    appears on dozens of other documents in the record. In any event petitioner offered no plausible explanation about where the money went if not to him. 4We do not believe that respondent was obligated to concede the inapplicability of the section 72(t) additional tax or the nontaxability of $737 in miscellaneous income.…
  4. Rev. Rul. 2011-7 — Section 403(b) plan termination. Final regulations under section 403(b) of the Code were published in 2007. Under the regulations a section 403(b) plan is perm…
    IRCRevenue RulingsMar 7, 2011
    INCOME TAX Rev. Rul. 2011-6 Rev. Rul. 2011-6 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 March 2011. Notice 2011-15 Notice 2011-15 Low-income housing ta…
  5. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    … and June 30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M. (CCH) 1707 (a case involving tax years 1979, 1980, and 1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d 825 (5th Cir. 1996) In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
  6. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011related by meaning
    …ess petitioner qualifies for an exception. See sec. 72(t) (1); see also Stipe v. Commissioner, T.C. Memo. 2011-92; Dollander v. Commissioner, T.C. Memo. 2009-187. Petitioner has not alleged that any exception applies, nor has he introduced any evidence that could allow us to conclude that an exception applies. Therefor…
  7. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
  8. 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,…
  9. Rev. Proc. 2011-49 — This procedure sets forth the procedures of the Service for issuing opinion and advisory letters regarding the acceptability under sections 401 and 403(a) of t…
    IRCRevenue ProceduresModified Oct 31, 2011
    …ervice’s Summer 2010 Retirement News for Employers. [4] See Rev.Proc. 2008-50, 2008-2 C.B. 464, and Memorandum for Directors, EP Examinations and EP Rulings & Agreements, dated March 11, 2009, as posted http:/www.irs.gov/pub/irs-tege/corrective_amendments.pdf. [5] Form 8717, User Fee for Employee Plan Determination, Op…
  10. 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
    wed 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.…
  11. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    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…
  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. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    … however, there was no levy by respondent in this case. Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13, affd. without published opinion 166 F.3d 1201 (2d Cir. 1998), also cited by petitioner, the taxpayer was indicted on charges of violating Federal currency transaction reporting laws. As part of the taxpaye…
  14. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    as the case may be) is due to reasonable cause and not to willful neglect. See sec. 6651(a)(1) and (2). - 8 - [*8] II. Discussion A. Deficiency in Tax Petitioner's 2013 Federal income tax return was due on April 15, 2014. See sec. 6072(a). In 2013, petitioner received a pension distribution of $208,111 ($166,489, after…
  15. Notice 2011-85 — This notice announces that the Treasury Department and the Service intend to amend the final regulations under section 411(b)(5) of the Code, which sets forth …
    IRCNoticesOct 31, 2011
    …der a cash balance or other statutory hybrid plan. Notices 2010-77 and 2010-90 modified. Rev. Proc. 2011-49 Rev. Proc. 2011-49 This procedure sets forth the procedures of the Service for issuing opinion and advisory letters regarding the acceptability under sections 401 and 403(a) of the Code of the form of pre-approve…
  16. Notice 2008-85 — This notice provides updated static mortality tables to be used in applying the minimum funding requirements to single employer defined benefit pension plans t…
    IRCNoticesOct 20, 2008
    …00 0.400000 120 1.000000 1.000000 1.000000 1.000000 1.000000 1.000000 1.000000 Mortality tables for 2011 Valuation dates occurring during 2011 Distributions subject to § 417(e)(3) with annuity starting dates during stability periods beginning in 2011 MALE MALE MALE FEMALE FEMALE FEMALE UNISEX Age 2011 Non-Annuitant Tab…
  17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  18. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
  19. 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…
  20. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    ry 27, 2011, check. The check did not clear, either because of the hold on petitioners' account (before February 28, 2011) or because the funds in the account had been transferred to the IRS (after February 28, 2011). Because petitioners' check did not clear, respondent reversed application of the check against their 2…