Notice 2010-36 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesApr 26, 2010
Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
April 2010 4.40 3.96 4.62
MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
IRCCourt RulingsJun 6, 2019related by meaning
…RS or respondent) to proceed by levy with collection of
her unpaid Federal income tax liability for 2010.
After a trial on the merits, the issues for decision are whether: (1) the
distribution that petitioner received from her retirement account is includable in
her gross income for 2010, (2) petitioner is liable for t…
Notice 2010-40 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesMay 24, 2010
rs Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
May 2010 4.40 3.96 4.62
MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
Notice 2010-47 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesJun 28, 2010
… Years Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
June 2010 4.39 3.95 4.61
MINIMUM PRESENT VALUE SEGMENT RATES
Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-mon…
IRCCourt RulingsOct 19, 2010related by meaning
ense that it caused.to surface a
meritorious section 72(t) issue and resulted in respondent's
I
"Respondent's concession is presumably based upon sec. 72(t) (2) (A) (iv), which provides that the 10-percent additional
tax does not apply to distributions which are "part of a series
of substantially equal periodic payment…
Notice 2010-70 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesNov 1, 2010
eginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
October 2010 4.28 3.85 4.49
MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
IRCCourt RulingsMay 19, 2011related by meaning
Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). Either party may move for
summary adjudication upon all or any part of the legal issues in controversy. Rule 121(a). Full or partial summary judgment is
appropriate where the record shows that there is no genuine issue
as to any material fact and that a decisi…
Notice 2010-76 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesNov 22, 2010
ginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
November 2010 4.26 3.83 4.47
MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
IRCCourt RulingsDec 30, 2013related by meaning
ss otherwise indicated, all section references are to the Internal
Revenue Code (Code) in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are
(continued...)
- 3 -
deficiency of $14,177 and an increased accuracy-related penalty of $3,435. A…
IRCCourt RulingsAug 13, 1990related by meaning
… to prove that there exist no genuine issues of material fact and that they are entitled to partial summary judgment as a matter of law. Petitioners argue that the questions on the Form 5500 series returns do not elicit disclosure of amounts originally advanced in years prior to the year for which the return is filed. …
IRCCourt RulingsNov 1, 2007related by meaning
…of the full assessment . 'Namely, the recapture penalty under sec . 72(t)(4)(A) .
- 9 -
Discussio n
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials . Fla . Peach Corp . v .
Commissioner , 90 T .C . 678, 681 (1988) . Summary judgment may be
granted where there is no genuine…
IRCCourt RulingsJun 4, 2014related by meaning
…or investigation as a result of information
provided by the whistleblower. IRM pt. 25.2.2 (June 18, 2010). Additionally, the Tax Court has exclusive jurisdiction over appeals of award
determinations where a whistleblower provided information both before and after
the effective date of TRHCA. See, e.g., Dacosta, 82 Fed.…
Notice 2008-85 — This notice provides updated static mortality tables to be used in applying the minimum funding requirements to single employer defined benefit pension plans t… IRCNoticesOct 20, 2008
…00 0.400000
120 1.000000 1.000000 1.000000 1.000000 1.000000 1.000000 1.000000
Mortality tables for 2010 Valuation dates occurring during 2010 Distributions subject to § 417(e)(3) with annuity starting dates during stability periods beginning in 2010
MALE MALE MALE FEMALE FEMALE FEMALE UNISEX
Age 2010 Non-Annuitant Tab…
IRCCourt RulingsOct 20, 2003related by meaning
result apparently so at
odds with accepted tax policy.” Darby v. Commissioner
, supra
at
68.
We find that petitioner did not have a basis in the 1999 distribution from his section 401(k) plan, and that petitioner
properly included the full distribution in his 1999 gross income.
Accordingly, we hold that petitioner is l…
IRCCourt RulingsFeb 10, 1997related by meaning
onsider its Opinion reported as Lucky Stores, Inc., & Subs. v.
Commissioner
, 107 T.C. 1 (1996). The Opinion is incorporated
herein by this reference. Except where otherwise noted, all Rule references are to the
Tax Court Rules of Practice and Procedure. All section
references are to sections of the Internal Revenue Co…
IRCCourt RulingsJun 25, 2013related by meaning
itioner may not have foreseen the tax consequences of his withdrawal
as structured in the MSA, the Supreme Court has held that "'[w]hile a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he
must accept the tax consequences of his choice, whether contemplated or not'".
Don E. W…
Notice 2014-77 — This notice contains the 2014 Cumulative List of Changes in Plan Qualification Requirements (2014 Cumulative List) described in section 4 of Rev. Proc. 2007–44… IRCNoticesDec 22, 2014
on or after January 1, 2010. (2010 C. L.)
Final Regulations under § 411(b)(5) were published on October 19, 2010 (75 Fed. Reg. 64123).[5] (2010 C. L.) Notice 2010–77 extends the deadline for amending cash balance and other applicable defined benefit plans, within the meaning of § 411(a)(13)(C), to meet the requirements…
IRCCourt RulingsDec 11, 2003related by meaning
f section 6501,
1
section 6651(a)(1),
2
- 37 -
2
(...continued)
(2003) ; Janpol v. Commissioner
, 102 T.C. 499, 503, 505 (1994);
Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, aff…
Notice 2012-76 — This notice contains the 2012 Cumulative List of Changes in Plan Qualification Requirements (2012 Cumulative List) described in section 4 of Rev. Proc. 2007-44… IRCNoticesDec 27, 2012
on or after January 1, 2010. (2010 C. L.)
Final Regulations under § 411(b)(5) were published on October 19, 2010 (75 Fed. Reg. 64123).[8] (2010 C. L.) Notice 2010-77, 2010-51 I.R.B. 851, extends the deadline for amending cash balance and other applicable defined benefit plans, within the meaning of § 411(a)(13)(C), to …
IRCCourt RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…