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…
IRCCourt RulingsJun 3, 1998related by meaning
…stituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a ruling
given to a specific taxpayer based upon the taxpayer's
specific facts and is not a ruling of general application.
See Golden Belt Tel. Association, Inc. v. Commissioner
, 108
T.C. 498, 506 (…
IRCCourt RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…
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…
T.D. 9471 — Final regulations under section 423 of the Code provide the requirements that must be satisfied in order for a plan to meet the definition of an employee stock… IRCTreasury DecisionsDec 7, 2009related by meaning
tions update the existing regulations and provide additional guidance in certain areas.
EXEMPT ORGANIZATIONS
Announcement 2009-86 Announcement 2009-86 The IRS has revoked its determination that the Gehrig and Margaret White Charitable Foundation of Charlotte, NC; and the Downs Family Foundation of Detroit, MI, qualify …
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…
T.D. 9695 — This treasury decision contains final regulations relating to the requirements for filing certain employee retirement benefit plan statements, returns, and rep… IRCTreasury DecisionsOct 14, 2014related by meaning
that are subject to various employee benefit plan reporting requirements under the Internal Revenue Code.
ADMINISTRATIVE
Notice 2014–57 Notice 2014–57 This notice provides the 2014–2015 special per diem rates for taxpayers to use in substantiating the amount of ordinary and necessary business expenses incurred while tr…
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 RulingsJan 16, 2020related by meaning
…tirement account. See Arnold v. Commissioner, 111 T.C.
250, 255 (1998); Adams v. Commissioner, T.C. Memo. 2015-162, at *8;
Dollander v. Commissioner, T.C. Memo. 2009-187. The Court may not add an
exception to the Code by judicial fiat, and we are obliged to apply the law as
written. See Iselin v. United States, 270 U.S…
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.…
Notice 2015-39 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2015 used under § 417(e)(3)(D), the 24-m… IRCNoticesJun 1, 2015related by meaning
INCOME TAX
Rev. Rul. 2015–14 Rev. Rul. 2015–14
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 June 2015.
Announcement 2015–15 Announcement 2015–15
The Offi…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
B. 2026-01 143
2026-4 2026-01 I.R.B. 2026-01 160
2026-5 2026-01 I.R.B. 2026-01 258
2026-6 2026-02 I.R.B. 2026-02 314
2026-7 2026-02 I.R.B. 2026-02 316 2026-8 2026-04 I.R.B. 2026-04 380
2026-9 2026-04 I.R.B. 2026-04 393
2026-10 2026-04 I.R.B. 2026-04 394
2026-12 2026-07 I.R.B. 2026-07 535
2026-13 2026-09 I.R.B. 2026-09 …
T.D. 9836 — These final regulations provide guidance regarding substantiation and reporting requirements for cash and noncash charitable contributions. The final regulatio… IRCTreasury DecisionsAug 13, 2018related by meaning
602.101 OMB Control numbers.
* * * * *
(b) * * *
______________________________________________________________
CFR part or section where Current OMB identified and described control No.
* * * * *
1.170A–15. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . …
IRCCourt RulingsOct 1, 2025related by meaning
…nce by taxpayers with the tax laws.”) ; IRM 5.8.11.3.3(1) ; see also
Bergevin v. Commissioner, T.C. Memo. 2008-6, 2008 W L 123931, at *9.
Factors supporting (but not conclusive of) a determination that
compromise would undermine compliance include, but are not limited
to, whether a taxpayer has taken deliberate action …
IRCCourt RulingsMay 29, 2002related by meaning
… however, there was no levy by respondent in this case.
Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13,
affd. without published opinion 166 F.3d 1201 (2d Cir. 1998),
also cited by petitioner, the taxpayer was indicted on charges of
violating Federal currency transaction reporting laws. As part
of the taxpaye…
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…
IRCCourt RulingsSep 25, 2019
professional basketball player who, in 2013, was convicted in Federal
court of wire fraud for running a real estate Ponzi scheme. See United States v. George, 684 F. App'x 223 (3d Cir. 2017). Petitioner was incarcerated for the
whole of 2013, and he has remained incarcerated to the present. He is scheduled
for release …
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-…
Notice 2016-29 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2016 used under § 417(e)(3)(D), the 24… IRCNoticesMay 2, 2016related by meaning
exemption from the individual shared responsibility payment because of a lack of affordable minimum essential coverage.
Notice 2016–30 Notice 2016–30 The Notice provides that the Service has designated, under I.R.C. section 7502(f), eight new delivery services as designated Private Delivery Services that qualify for t…
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…