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Go to T.C. Memo. 2012-252 (not yet in the library — opens the official source)
77 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. REG-113891-07 — Part IV. Items of General Interest
    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 …
  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
    …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…
  3. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    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 …
  4. 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…
  5. 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…
  6. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    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…
  7. 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…
  8. 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…
  9. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
    IRCCourt RulingsAug 28, 2008related by meaning
    T .C . Memo . 2008-20 4 UNITED STATES TAX-COUR T WALTER KOWSH, Petitioner v . COMMISSIONER OF . INTERNAL . REVENUE, Responden t Docket No . 15154-06 . Filed August 28, 2008 . Walter Kowsh, pro se . Michelle L . Maniscalco , for respondent . MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N KROUPA, Judge : Respondent determined…
  10. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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…
  11. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    Commissioner's determination for abuse of discretion. E2, Sego v. - 18 - [*18] Commissioner, 114 T.C. at 610. The Appeals Office abuses its discretion when its exercise of discretion is arbitrary, capricious, or without sound basis in fact or law. Murphy v. Commissioner, 125 T.C. 301, 308, 320 (2005), aff'd, 469 F.3d 2…
  12. 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…
  13. 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…
  14. 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…
  15. T.C. Memo. 2017-201 — Joseph E. Bormet v. Commissioner
    IRCCourt RulingsOct 16, 2017related by meaning
    T.C. Memo. 2017-201 PA UNITED STATES TAX COURT JOSEPH E. BORMET, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6863-16. Filed October 16, 2017. Bradley S. McCann, for petitioner. Angela B. Reynolds and Briseyda Villalpando, for respondent. MEMORANDUM OPINION GOEKE, Judge: Respondent determined a…
  16. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011related by meaning
    under section 72(t) for an early distribution from a qualified retirement plan in 2005.' 'The 10-percent additional tax applies only to the TSP loans that petitioner failed to repay. Respondent did not assert in (continued...) - 11 - IV. Conclusion In summary, we conclude that (1) petitioner received taxable disability…
  17. T.D. 9256 — Final regulations under section 417 of the Code concern content requirements applicable to explanations of qualified joint and survivor annuities and qualified…
    IRCTreasury DecisionsApr 17, 2006related by meaning
    SPECIAL ANNOUNCEMENT Announcement 2006-22 Announcement 2006-22 This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA program during calendar year 2005. This document does not provide guidance regarding the application of the arm’s length standa…
  18. 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…
  19. T.C. Memo. 2012-166 — Todd R. & Andrea Pedersen v. Commissioner
    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.
  20. 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 (…