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Go to T.C. Memo. 2011-243 (not yet in the library — opens the official source)
75 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011related by meaning
    …not necessarily disabled within the meaning of I section 72(m) (7). See Kopty v. Commissioner, T.C. Memo; 2007-343 (taxpayer who received long-term disability benefits from the U.S. Social Security Administration nct disabled within the' meaning of section 72(m) (7)), affd. 313 Fed. Appx. 333 (D.C. Cir. 2009); see also…
  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. 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…
  4. 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 …
  5. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    limitation would have expired. - 11 - Nor does the fact that respondent had already issued petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected items notice of deficiency to petitioners for the same year. See sec. 6230(a)(2)(C); Hemmings v. Commissio…
  6. 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…
  7. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
  8. 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…
  9. T.C. Memo. 2011-31 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsFeb 1, 2011related by meaning
    ximum sanction under section 6673(a) (1) is appropriate. We shall require petitioner to pay a $25,000 penalty under section 6673(a) (1) in each of the consolidated cases. V. Conclusion We conclude that (1) petitioner is liable for a reduced deficiency and additions to tax for 20Ø4 as respondent conceded, and (2) petiti…
  10. T.C. Memo. 2008-142 — Michael Cabirac v. Commissioner
    IRCCourt RulingsMay 22, 2008related by meaning
    SERVIC E T .C . Memo . 2008-14 2 UNITED STATES TAX COUR T MICHAEL CABIRAC, Petitioner v . COMMISSIONER OF INTERNAL RE ENUE, Responden t Docket No . 24207-06 . Filed May 22, 2008 . Michael Cabirac, pro se . James H . Harris, Jr . , for respon d MEMORANDUM FINDINGS OF FACT AND OPINIO N FOLEY, Judge : The issues for decis…
  11. T.C. Memo. 2023-141 — Danielle Monique Scott v. Commissioner
    IRCCourt RulingsNov 28, 2023related by meaning
    tion she received in 2019. ” Petitioner did not respond t o our Order by the October 2, 2023, deadline or subsequently. Discussion I. Summary Judgment The purpose of summary judgment is to expedite litigation and avoid costly, time-consuming, and unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (…
  12. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    T.C. Summary Opinion 2013-51 UNITED STATES TAX COURT MARTIN TOOMBS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27665-10S. Filed June 25, 2013. James O. Creech III, for petitioner. Thomas D. Yang, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the p…
  13. 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…
  14. T.C. Memo. 2017-125 — Jeremy Ray Summers v. Commissioner
    IRCCourt RulingsJun 26, 2017related by meaning
    e requirements of the QDRO provisions must be "rigidly observed" because they "relate to the substance or essence of the statute"). We have con- - 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help minimize stress on his soon-to-be ex-wife disabled him from satisfying the statutor…
  15. 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…
  16. 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,…
  17. 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…
  18. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016related by meaning
    SYM T.C. Memo. 2016-31 UNITED STATES TAX COURT BRIAN M. POLOWNIAK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 20589-11, 20606-11. Filed February 25, 2016. Harry Charles, for petitioner. Blaine C. Holiday and Wesley J. Wong, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PARIS, Judge…
  19. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    petitioners may wish to submit, any new collection alternative that petitioners may wish to propose, and any asserted change in circumstances. - 40 - [*40] We have considered the parties' remaining arguments and, to the extent not discussed above, conclude that those arguments are irrelevant, moot, or without merit. Fo…
  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…