IRCCourt RulingsJul 8, 2020related by meaning
BD
T.C. Memo. 2020-101
UNITED STATES TAX COURT
TAMECCA SERIL, a.k.a. TAMECCA TILLARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4491-19. Filed July 8, 2020.
Tamecca Seril, a.k.a. Tamecca Tillard, pro se.
Marissa J. Savit and Thomas A. Deamus, for respondent.
MEMORANDUM FINDINGS OF FACT AND O…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
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…
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.…
IRCCourt RulingsDec 29, 2005related by meaning
. ADM. ||
RVICE
STAT.
. . |S57-f JUDGE
' j FILES 042 t
T.C. Memo. 2005-298
UNITED STATES TAX COURT
ISABELLE BICHINDARITZ, Petitioner 1.
COMMISSIONER OF INTERNAL REVENUE, Respondént
Docket No. 16098-0.3. Filed December 29, 2005.
Scott A. Schumacher, for petitioner.
Catherine L. Campbell, for respondent.
MEMORANDUM FINDI…
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…
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.…
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 …
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…
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…
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…
IRCCourt RulingsJun 13, 2012related by meaning
ion of the stock in an S
corporation), nor the penalties determined by respondent.
- 27 -
For the reasons stated,
Appropriate orders will be issued in docket Nos. 6000-09 and 6449-09, and
decisions will be entered for petitioners in
docket Nos. 5999-09., 6290-09, 6303-09,
and 12128-09.
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…
T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr… IRCTreasury DecisionsDec 9, 2013related by meaning
INCOME TAX
Rev. Rul. 2013–26 Rev. Rul. 2013–26
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 December 2013.
EMPLOYEE PLANS
T.D. 9641 T.D. 9641
These final…
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 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…
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…
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…
IRCCourt RulingsJan 5, 2017related by meaning
65 cz
T.C. Memo. 2017-5
UNITED STATES TAX COURT
BRIAN E. HARRISS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 12528-14, 25358-14. Filed January 5, 2017.
Brian E. Harriss, pro se.
Randall B. Childs and Caroline R. Krivacka, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge…
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…