Notice 2012-67 — 2013 cost-of-living adjustments; retirements plans, etc. This notice sets forth certain cost-of-living adjustments effective January 1, 2013, applicable to the… IRCNoticesDec 10, 2012
INCOME TAX
Rev. Proc. 2012-46 Rev. Proc. 2012-46
General rules and specifications for substitute Form 941 and Schedule B (Form 941), and Schedule R (Form 941). This procedure provides general rules and specifications from the Service for paper and computer-generated substitutes for Form 941, Schedule B (Form 941) and S…
IRCProposed Rules (FR)Proposed Oct 15, 2007
… under paragraph (e) of this section, and benefit accruals resume under Plan T beginning January 1, 2012, unless Plan T provides otherwise. Example 4. (i) The facts are the same as in Example 3, except that the enrolled actuary for the plan does not issue a certification of the AFTAP for 2011 for Plan T until February …
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…
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
…as determined dividends in the same manner for the 60-month period immediately preceding January 1, 2012. The plan sponsor continues to determine dividends in the same manner for dividends declared as of March 31, 2012, June 30, 2012, and December 31, 2012, but declares a reduced dividend as of September 30, 2012. Assu…
IRCCourt RulingsApr 20, 2017
…4, Pub. L. No. 93-445, sec. 10(c), 88 Stat. at 1344 (codified
as amended at 45 U.S.C. sec. 231i(c) (2012)); Railroad Unemployment Insurance
Act Amendments, ch. 842, sec. 11, 54 Stat. at 1096 (1940) (codified as amended at
- 46 -
45 U.S.C. sec. 352(d) (2012 & Supp. I 2013)) (all using the phrase "against equity
or good …
IRCCourt RulingsAug 19, 2009related by meaning
…al hardship is not one of the
exceptions in section 72(t)(2) . See Milner v . Commissioner , T .C .
Memo . 2004-111 (no "umbrella hardship exception") ; Gallagher v .
Commissioner , T .C . Memo . 2001-34 ("There is, however, no hardship
exception in the controlling statutes .") .
. . .continued)
(A) the Thrift Savings …
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
88 FR 71287 — Requirements for Type I and Type III Supporting Organizations IRCFinal Rules (FR)Oct 16, 2023
TD). Also on December 28, 2012, the Treasury Department and the IRS published a notice of proposed rulemaking (REG-155929-06) in the
Federal Register (77 FR 76426) containing proposed regulations that incorporated the text of the temporary regulations in the 2012 TD by cross-reference. The temporary regulations in the…
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 …
81 FR 8446 — Requirements for Type I and Type III Supporting Organizations IRCProposed Rules (FR)Proposed Feb 19, 2016
alify as a Type III supporting organization under the PPA.
On December 28, 2012, the Treasury Department and the IRS published in the
Federal Register (77 FR 76382) a Treasury decision (TD 9605) containing final and temporary regulations (the 2012 TD) regarding the requirements to qualify as a Type III supporting organ…
80 FR 79684 — Payout Requirements for Type III Supporting Organizations That Are Not Functionally Integrated IRCFinal Rules (FR)Dec 23, 2015
alify as a Type III supporting organization under the PPA.
On December 28, 2012, the Treasury Department and the IRS published in the
Federal Register (77 FR 76382) a Treasury decision (TD 9605) containing final and temporary regulations (the 2012 TD) regarding the requirements to qualify as a Type III supporting organ…
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…
Ann. 2012-7 — This document contains a correction to Rev. Proc. 2012-8, 2012-1 I.R.B. 235, which contains a typographical error in section 6.07(5). This announcement correct… IRCAnnouncementsFeb 6, 2012
Announcement 2012-7
Correction to Revenue Procedure 2012-8
Revenue Procedure 2012-8 as published on January 3, 2012 (2012-1 I.R.B. 235) contains a typographical error in section 6.07(5). The error is that section 6.07(5) refers to Notice 2011-34. The correct Notice is Notice 2011-43. Section 6.07(5) is amended to de…
IRCCourt RulingsDec 13, 2012related by meaning
CLC
T.C. Memo. 2012-344
UNITED STATES TAX COURT
KARL E. CROSS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6009-09. Filed December 13, 2012.
Mitchell Stuart Fuerst and Joseph A. DiRuzzo III, for petitioner.
Brian E. Derdowski, Jr., and Carroll De Groff Lansdell, for respondent.
MEMORANDUM OPIN…
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 RulingsSep 25, 2019related by meaning
… T.C. 518, 520
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[*11] (1992), affd, 17 F.3d 965 (7th Cir. 1994); Murphy v. Commissioner, T.C.
Memo. 2019-72, at *7.
The regulations provide that a taxpayer has reasonable cause for failure to
timely pay a tax if "the taxpayer has made a satisfactory showing that he exercised
ordinary business care and prudence in…
IRCCourt RulingsJan 22, 2025related by meaning
United States Tax Court
T.C. Memo. 2025-7
SONJI MARIE MOSLEY ,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
__________
Docket No. 11872-22. Filed January 22, 2025.
__________
Sonji Marie Mosley , pro se.
Xheni D. Gallagher, Timothy R. Prosky, and Olivia H. Rembach , for
respondent.
MEMORANDUM OPINION
ASHF…
IRCCourt RulingsJul 13, 2010related by meaning
all of the contentions and arguments of
the parties that are not discussed herein, and we conclude that
they are without merit, irrelevant, or moot . "Para . 6 of the petition filed by each petitioner admits
:
"According to Section 6673, this court may penalize Petitioner up
to $25,000 for failure to complete the admin…
IRCCourt RulingsDec 19, 1995
…fer Refund does not constitute a qualified total
distribution. See Wittstadt v. Commissioner
, T.C. Memo. 1995492; Humberson v. Commissioner
, T.C. Memo. 1995-470; Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 ; Adler v. Commissioner
, T.C.
Memo. 1995-148; Dorsey v. Commissioner
, T.C. Memo. 1995-97; Brown
v. Commissi…
IRCCourt RulingsApr 2, 2020related by meaning
…
T.C. 85, 101 (2004); Keller v. Commissioner, 568 F.3d 710, 718 (9th Cir. 2009),
aff'g in part T.C. Memo. 2006-166, and aff'g in part, vacating in part decisions in
related cases. Goldberg resided in Illinois when he filed his petition. Therefore
our decision will not be appealable to the First, Eighth, or Ninth Circui…