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Go to T.C. Summary Op. 2005-80 (not yet in the library — opens the official source)
69 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    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…
  2. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    63 3. Analysis and holding... . . ..... . .. . . . ...... . . . . . . . . . . 66 D. Intermediary period: September 28 through November 30, 2007 . . 67 E. Period 3: December 1, 2007, through January 31, 2008 . . . . . . . . . 68 1. Introduction....................................... 68 2. Events ........................…
  3. Rev. Rul. 2004-104 — 2005 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2005 are provided for use in …
    IRCRevenue RulingsNov 15, 2004
    EMPLOYEE PLANS Rev. Rul. 2004-104 Rev. Rul. 2004-104 2005 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2005 are provided for use in determining contributions to defined benefit plans and permitted disparity. Notice 2004-72 Notice 2004-72 20…
  4. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    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.…
  5. T.D. 9072 — Final regulations under section 414(v) of the Code provide guidance on the requirements for retirement plans providing for catch-up contributions to individual…
    IRCTreasury DecisionsSep 15, 2003
    …plan year that is not the calendar year. For example, in a plan with a plan year ending on June 30, 2005, elective deferrals in excess of the employer-provided limit or the ADP limit for the plan year ending June 30, 2005, would be treated as catch-up contributions as of the last day of the plan year, up to the catch-u…
  6. Treas. Reg. § 1.409(p)-1T(h) — Prohibited allocations of securities in an S corporation (temporary).
    IRCRegulationsMay 18, 2016
    icequity shares on determination date January 1, 2005 A grant is made on January 1, 2005 with a present value of $1,000. An additional grant of nonqualified deferred compensation with a present value of $775 is made on March 1, 2005 $10 per share 100 100 January 1, 2006 An additional grant is made on December 31, 2005 …
  7. PLR 200737046 — Tax on Prohibited Transactions
    IRCPrivate Letter RulingsSep 14, 2007related by meaning
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  8. 101 T.C. 189; 101 T.C. No. 12 — Lee Eng'g Supply Co. v. Commissioner
    IRCCourt RulingsAug 30, 1993related by meaning
    ferences are to the Internal Revenue Code in effect for the years in issue, and Rule references are to the Tax Court Rules of Practice and Procedure.↩ 1. To be determined.↩ 2. The $ 53 difference between the $ 6,853 amount appearing on the FYE 1985 Form 5500-C and the $ 6,800 amount appearing in the statutory notice of…
  9. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM Third Party Communication: None Date of Communication: Not Applicable Number: 200648028 Release Date: 12/1/2006 Index (UIL) No.: 6166.00-00, 6403.00-00, 2055.00-00, 2511.02-00, 414 .00-00, 2053.09-00, 2032.00-00 CASE - MIS No.: TAM - 142156-05 AUGUST …
  10. Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in …
    IRCRevenue RulingsDec 28, 2009related by meaning
    Rights II, the Internal Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004. REG-111833-99 REG-111833-99 Proposed regulations under section 7430 of the Code relate to awards of administrative costs and attorneys fees to conform the regulations to the amendments made in the …
  11. Rev. Proc. 2006-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section…
    IRCRevenue ProceduresSuperseded Jan 3, 2006
    or subsequent years, in accordance with the rules set forth in Rev. Proc. 2005-66. Other Guidance .03 Other guidance affecting this revenue procedure: Rev. Proc. 2005-16, 2005-10 I.R.B. 674, describes the procedures for the “pre-approval” of plans under the master and prototype (M&P) program and the volume submitter (V…
  12. T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a …
    IRCTreasury DecisionsMay 7, 2007related by meaning
    … the Archer Medical Savings Account (Archer MSA) pilot program under section 220(j)(2) of the Code, 2005 and 2006 are not cut-off years. EMPLOYEE PLANS T.D. 9321 T.D. 9321 Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a defin…
  13. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsMar 3, 2000related by meaning
    DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 October 15, 1999 Number: 200009002 Release Date: 3/3/2000 CC:EBEO:4 TL-N-4712-99 UILC: 419.00-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR FROM: Assistant Chief Counsel (Employee Benefits and Exempt Organizatio…
  14. 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
    …erning 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 standard. Instead, it reports on the structure and activities of the APA program. INCOME TAX Notice 2006-38 Notice 2006-38 This …
  15. Treas. Reg. § 1.424-1(e)(7) — Definitions and special rules applicable to statutory options.
    IRCRegulationsJan 19, 2017
    2005, and on or before June 1, 2006. On June 1, 2004, the fair market value of X Corporation's stock is $100 per share. On February 1, 2005, X Corporation modifies the option to provide that the option shall be exercisable on or before September 1, 2006. On February 1, 2005, the fair market value of X Corporation stock…
  16. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … to the internal revenue laws shall be applied without retroactive effect. Section 15 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular tax…
  17. PLR 201927010 — Applicable Defined Benefit Plans
    IRCPrivate Letter RulingsJul 5, 2019
    …CSEC plan with respect to any given plan year, the plan must (1) have been in existence on July 26, 2005, (2) be a single plan mai ntained by more than one employer during the plan year that includes July 26, 2005 and each subsequent plan year through and including the plan year in question, and (3) satisfy the 85 perc…
  18. T.C. Memo. 2011-83 — Bruce A. & Carol Anfinson Brown v. Commissioner
    IRCCourt RulingsApr 12, 2011
    to exceed the policy's cash value, and Northwestern terminated the policy on | January 6, 2005. On February 16, 2005, Northwestern restored the policy because Mr. Brown made a $559 "minimum interest payment" of which $428.04 went to interest and $130.96 went to principal. On March 21, 2005, Mr. Brown made a final cash …
  19. T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover …
    IRCTreasury DecisionsMar 23, 2009related by meaning
    on 414(w) for the entire plan year (or the portion of the plan year that the eligible NHCEs and eligible HCEs are eligible employees under the plan)). Qualified nonelective contributions and qualified matching contributions taken into account under §1.401(k)-2(a)(6) of this Chapter or qualified nonelective contribution…
  20. T.C. Memo. 2011-31 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsFeb 1, 2011
    … filing separately, and one exemption, and he sought a refund of $8,593. Petitioner attached to the 2005 Form 1040 a Form 4852 reflecting zero wages for 2005. Petitioner wrote "Non assumpsit by" above his signature on the jurats of the Form 1040 and Form 4852. Petitioner also attached a 67-page document entitled "Notic…