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,…
IRCPrivate Letter RulingsJan 15, 2016related by meaning
Office of Chief Counsel
Internal Revenue Service
memor andum
Number: 201603025
Release Date: 1/15/2016
CC:TEGE:EB:EC
POSTU - 107896-14
UILC: 409A.00-00, 409A.01-00
date : September 30, 2015
to : R. Scott Shieldes
Associate Area Counsel (Houston, Group 1)
(Large Business & International)
from : John B. Richards, Senior …
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 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 RulingsSep 28, 2011related by meaning
T.C. Summary Opinion 2011-113
UNITED STATES TAX COURT
GAIL MARIE WATSON, Petitioner v.
COMMISSIONER- OF INTERNAL REVENUE, Respondent
Docket No. 14769-10S. Filed September 28, 2011.
Gail Marie Watson, pro se . . ..
Ryan M. Wyzik, for respondent. .
DAWSON, Judge: The petition' in this case was filed pursuant
to the provi…
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…
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 RulingsSep 25, 2019★ strong match
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 …
Rev. Rul. 2014-18 — This ruling provides that a nonstatutory stock option or a stock appreciation right (each, a stock right) granted by a nonqualified entity for purposes of sect… IRCRevenue RulingsJun 23, 2014related by meaning
d restrictions relating to such practice and prescribe the disciplinary sanctions for violating the regulations.
Rev. Proc. 2014–35 Rev. Proc. 2014–35 This revenue procedure provides safe harbors for applying the general welfare exclusion to Indian tribal government programs that provide benefits to tribal members.
Not…
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 RulingsMay 25, 2005related by meaning
…nse of unnecessary trials. Fla. Peach Corp. v.
Commissioner
, 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121. The moving party bears the burden of proving that
there is no genuine issue…
IRCCourt RulingsSep 23, 2019related by meaning
T.C. Summary Opinion 2019-26
PA
UNITED STATES TAX COURT
PASCAL NSAME AND LAMIAA MSALKA, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11462-15S. Filed September 23, 2019.
Pascal Nsame and Lamiaa Msalka, pro sese.
Timothy B. Heavner and Mary Ann Waters, for respondent.
SUMMARY OPINION
COLVIN, Ju…
IRCCourt RulingsJan 16, 2020related by meaning
bed in section 72(t) in respect of Mr. Merrell's IRA
distribution is sustained.
As a final matter, petitioners maintain that they will suffer economic hardship if the additional tax prescribed in section 72(t) is imposed in this case.
We have considered similar claims in the past and have observed that there is no
-8au…
IRCCourt RulingsJul 25, 2005related by meaning
settlement
agreement is not a qualified domestic order, and Mr. Ahmad is not
an alternate payee, the exception in section 72(t)(2)(C) is
inapplicable. In light of the foregoing, the Court holds that petitioners
are liable for the 10-percent additional tax imposed under
section 72(t).
Reviewed and adopted as the report …
Notice 2013-6 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesMar 4, 2013
…g in 2012, the three adjusted 24-month average corporate bond segment rates applicable for February 2013, taking into account the applicable percentage of the 25-year average segment rates, are as follows:
Adjusted 24-Month Average Segment Rates, Using Applicable Percentage of 25-Year Average Segment Rates
Applicable M…
Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co… IRCRevenue ProceduresDec 30, 2024related by meaning
ounting method involving only one of the items or sub-methods.
(4) The tax effect of any transaction to be consummated at some indefinite future time. (5) Any matter dealing with the question of whether property is held primarily for sale to customers in the ordinary course of a trade or business.
(6) The tax effect of…
IRCCourt RulingsFeb 26, 2014related by meaning
s a 4 µ
T.C. Summary Opinion 2014-18
UNITED STATES TAX COURT
THOMAS WESLEY ALEXANDER AND SYLVIA ALEXANDER, Petitioners y.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1764-12S. Filed February 26, 2014.
Walter B. Smith, for petitioners.
Jeremy D. Cameron and Peter T. McCary, for respondent.
SUMMARY OPINION
DE…
IRCCourt RulingsSep 26, 2001related by meaning
…e
references are to the Tax Court Rules of Practice and Procedure,
unless otherwise indicated.
T.C. Summary Opinion 2001-158
UNITED STATES TAX COURT
MAJID NAEMI, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8339-00S. Filed September 26, 2001.
Majid Naemi, pro se.
Michele A. Yates
, for respond…
IRCCourt RulingsNov 7, 1996related by meaning
is written, and, even if
petitioner's argument might accord with good policy, we are not
at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy
, 516
U.S.
116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing
Badaracco v. Commissioner
, 464 U.S. 386, 398 (1984))…
131 T.C. No. 4 — Ralston Purina Company and Subsidiaries v. Commissioner IRCCourt RulingsSep 10, 2008related by meaning
are petitioner's and
respondent's cross-motions for summary ·judgment pursuant to Rule
121.
Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code in effect for the
years in 1ssue.
Rule 121(a) provides that either…