IRCCourt RulingsJul 11, 2024related by meaning
).
VIII. Conclusion
Petitioners received railroad retirement and Social Security
benefits from the RRB during each of the years in issue . Petitioners have failed to prove that respondent incorrectly determined the
adjustments to petitioners’ income on the basis of amounts that were
not reported in the information retu…
IRCCourt RulingsSep 17, 2026related by meaning
…tt v.
Commissioner, 160 T.C. 534, 542 n.4 (2023).
I. Petitioner’s C laim for A ward
O n February 3, 2013, petitioner filed Form 211, Application for
Notice 2013-28 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in April 2013; the 24-month average segment rates; … IRCNoticesMay 6, 2013
…nding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from March 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of March 2013 are, respectively, 0.97, 3.82, and 5.11. For plan years beginning on or after January 1, 2012…
Notice 2013-37 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in June 2013; the 24-month average segment rates; t… IRCNoticesJun 24, 2013
…funding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from May 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of May 2013 are, respectively, 0.97, 3.76, and 5.01. For plan years beginning on or after January 1, 2012, …
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…
Notice 2013-46 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in July 2013; the 24-month average segment rates; t… IRCNoticesJul 29, 2013
…unding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from June 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of June 2013 are, respectively, 1.24, 4.25, and 5.43. For plan years beginning on or after January 1, 2012,…
IRCCourt RulingsMay 5, 2015
…was a "bigger issue"--petitioners' failure to make sufficient estimated tax payments to cover their 2013 Federal tax
liability. Specifically, SO Okubena told Mr. Curosh that the $43,000 of estimated
tax payments that petitioners had made so far was insufficient to cover their 2013
- 11 -
[*11] tax liability and that sh…
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…
Notice 2013-84 — This notice contains the 2013 Cumulative List of Changes in Plan Qualification Requirements (2013 Cumulative List) described in section 4 of Rev. Proc. 2007–44… IRCNoticesDec 23, 2013
Notice 2013–84
2013 Cumulative List of Changes in Plan Qualification Requirements
I. PURPOSE
This notice contains the 2013 Cumulative List of Changes in Plan Qualification Requirements (2013 Cumulative List) described in section 4 of Rev. Proc. 2007–44, 2007–2 C.B. 54. The 2013 Cumulative List is to be used by plan spo…
IRCCourt RulingsJun 13, 2017related by meaning
JRN
T.C. Memo. 2017-112
UNITED STATES TAX COURT
WHISTLEBLOWER 19860-15W, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19860-15W. Filed June 13, 2017.
Sealed,¹ for petitioner.
Ashley M. Bender and Richard L. Hatfield, for respondent.
MEMORANDUM OPINION
KERRIGAN, Judge: This case is before the Co…
Rev. Proc. 2014-28 — This revenue procedure modifies Rev. Proc. 2013–22, 2013–18 I.R.B. 985, which sets forth the procedures of the Internal Revenue Service (Service) for issuing o… IRCRevenue ProceduresApr 14, 2014
Rev. Proc. 2014–28
SECTION 1. PURPOSE
This revenue procedure modifies Rev. Proc. 2013–22, 2013–18 I.R.B. 985, which sets forth the procedures of the Internal Revenue Service (Service) for issuing opinion and advisory letters for § 403(b) pre-approved plans (that is, § 403(b) prototype plans and § 403(b) volume submitte…
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…
Rev. Proc. 2013-12 — This procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sectio… IRCRevenue ProceduresJan 22, 2013
…ment Program (“Audit CAP”). Rev. Proc. 2008-50 modified and superseded.
ADMINISTRATIVE
Announcement 2013-9 Announcement 2013-9 This announcement addresses a typographical error in the Schedule of User Fees found in Appendix A of Revenue Procedure 2013-1, 2013-1 I.R.B. 1, wherein the reduced user fee for a letter ruling…
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…
IRCCourt RulingsAug 31, 2021related by meaning
including granting CNC status - - s ince petitioner did not furnish necessary
documentation. On the basis of these circumstances M s. Rego performed a balancing test, concluding that the proposed levy did balance the needs of
collection with the concerns of petitioner. On the basis of our review w e hold that
M s. Rego…
IRCCourt RulingsJan 3, 2017related by meaning
v.
Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo.
2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v.
- 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001).
While we acknowledge and are sympathetic to petitioner's financial straits, we
have no aut…
IRCCourt RulingsDec 19, 2000related by meaning
…nt from issuing the affected
items notice of deficiency to petitioners for the same year. See
sec. 6230(a)(2)(C); Hemmings v. Commissioner
, 104 T.C. 221, 226
n.6 (1995); Boyd v. Commissioner
, 101 T.C. 365, 372-73 (1993).
Petitioners rely incorrectly on Roberts v. Commissioner
, 94 T.C.
853 (1990), for a contrary resu…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026related by meaning
nnual period.
ACTION ON DECISION
Subject: Mohamed K. Abdo and Fardowsa J. Farah v. Commissioner, 162 T.C. 148 (April 2, 2024) (reviewed by the court). Issue: Whether the originally enacted version of 26 U.S.C. § 7508A(d)1 provided for an automatic and mandatory 60-day postponement of certain tax-related deadlines for a…
IRCCourt RulingsSep 21, 2017
es of $53,114 from AT&T in 2013 and $5,984
from Ad Susman & Associates, Inc., in 2014.
After losing his job with AT&T Mr. Pokawa withdrew money from a retirement account to invest in various business activities. The withdrawals were
reported on Forms 1099-R, Distributions From Pensions, Annuities, Retirement or
Profit-…
IRCCourt RulingsMay 6, 2014
…upon an opinion rendered by this Court on June 8, 2009, in HIE Holdings, Inc. v. Commissioner, T.C. Memo. 2009-130 (deficiency case),
affirmed by the Court of Appeals for the Ninth Circuit on April 5, 2013, 521 Fed.
'All section references are to the Internal Revenue Code (Code) in effect at
all relevant times, and all…