IRCPrivate Letter RulingsMay 10, 2002
Internal Revenue Service
Number: 200219002
Release Date: 5/10/2001
Index Number: 419.00-00 419.14-00
4976.00-00 4976.01-00
Department of the Treasury
Washington, DC 20224
Person to Contact:
Telephone Number:
Refer Reply To:
CC:TEGE:EB:HW:PLR-125981-00
Date:
09/28/2001
LEGEND:
Taxpayer =
Trust=
Council =
Holding Company…
PLR 200205007 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsFeb 1, 2002
…le.
This ruling is directed only to X and applies only to the plan and trust submitted
on April 11, 2001, as revised by amendments submitted on September 25, 2001 and
October 19, 2001. Section 6110(k)(3) of the Code provides that it may not be used or
cited as precedent.
Temporary or final regulations pertaining to one…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016related by meaning
section. Such conduct shall be subject to the penalties prescribed by sections 212(n)(2)(C)(ii) or (t)(3)(C)(ii) of the INA and § 655.810(b)(2),
i.e., a fine of up to $7,251, disqualification from filing petitions under section 204 or section 214(c) of the INA for at least two years, and such further administrative rem…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
IRCCourt RulingsAug 4, 2005
of the distribution was
used to pay qualified higher education expenses in the taxable
year 2001, the issue is whether petitioners are subject to the 10-percent additional tax under section 72(t)(1) on the remaining
$17,982.99. Petitioners resided in Liberty Township, Ohio, at
the time the petition was filed.
Backgrou…
IRCCourt RulingsJan 5, 2017related by meaning
n 6662(a) and (b)(1) and (2), a taxpayer may be liable for a penalty of20%
5 Over petitioner's objection respondent introduced a literal transcript of account for petitioner's 2010 tax year. The literal transcript contains no reference
to any SFRs. Even if it did, the literal transcript does not establish that the
requ…
PBGCProposed Rules (FR)Proposed Jul 22, 2010related by meaning
debtor's employing agency or to the Financial Management Service to implement salary offset, unless the employee files a timely request for a hearing; (v) That a final decision on the hearing, if requested, will be issued at the earliest practicable date, but not later than 60 days after the filing of the request for a…
IRCCourt RulingsAug 8, 2005
…
WELLS, Judge
: Respondent determined a deficiency of $2,764
in petitioner’s Federal income tax for 2001. The issue to be
decided is whether petitioner’s 2001 gross income includes the
amount of a check petitioner received but did not cash in 2001.
All section references are to the Internal Revenue Code (Code),
- 2 -
a…
IRCCourt RulingsMay 14, 2009
… in rent and royalty losses of $13,796
._
for 1999
. Respondent's'computer printout of petitioners' 2001
Schedule E shows that petitioners did not report any rent
6 _
received, depreciation expense, or other expenses related to the
two residential rental properties but claimed .a .rent and royalty
loss of $12,480 for 2…
IRCCourt RulingsJan 3, 2011
…747, 1955 -2 C. B/228d Notice 20 01-10 , supra, revoked Rev. Rul. 55-747, supra, and provided Table 2001
as a substitute for the P.S. 58 rates
In, Curc io-v . Commis s ioner , T . C . Memo 2010 -115 , we used the
rates in section 1.79-3 (d) , Income Tax Regs. as a "rough
estimate" of'the cs c life insurance protection …
IRCCourt RulingsDec 8, 1987related by meaning
ssioner argues that such returns did not adequately disclose the prohibited transactions and that therefore the 6-year statute of limitations applies. Whether a return adequately discloses an item of income or a transaction is a question of fact. See Quick Trust v. Commissioner, 54 T.C. 1336, 1346 (1970), affd. per cur…
IRCCourt RulingsJul 12, 2005
nuary 2 payment as income for 2001.
In a statement dated January 16, 2001, USAA informed
petitioner that she had a vested balance of $11,929.32 and an outstanding loan of $10,480.27 in her USAA SIP account as of that
date. Petitioner was informed that she had to pay her
outstanding loan balance by April 17, 2001, or it…
IRCCourt RulingsJul 25, 2012related by meaning
ch an addition to
tax applies under both paragraphs. Sec. 6651(c)(1).
- 10 -
Under section 6020(b), when a taxpayer fails to-file a return required'by law, the Commissioner (acting for the Secretary of the Treasury) may make a
return from such information as it can obtain. Under section 6651(g)(2), any
return so made i…
IRCCourt RulingsAug 1, 2005
…able portion of his
distribution check. In response, Americo sent petitioner a
letter, dated May 9, 2001, requesting petitioner to: (1) Return
the policy contract or submit written acknowledgment that the
policy had been lost or destroyed, and (2) submit written
acknowledgment of the reason or eligibility for a direct
…
IRCFinal Rules (FR)Nov 8, 2011related by meaning
sthroughs and Special Industries), IRS.
List of Subjects in 26 CFR Part 20
Estate taxes
Reporting and recordkeeping requirements
( printed page 69128) Adoption of Amendments to the Regulations
Accordingly, 26 CFR part 20 is amended as follows:
PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954
Paragra…
IRCCourt RulingsJun 6, 2005
…as filed. Petitioners, Victor A. and Esther Suarez, are husband and
wife. During the year in issue (2001), they were homeowners of
property at 4934 Raffaele Drive, in Sierra Vista, Arizona. In
2001, Victor A. Suarez (hereinafter petitioner) withdrew $33,590
1
from his Individual Retirement Account (IRA). He received th…
T.D. 9237 — Final regulations under section 401 of the Code provide guidance concerning the requirements for designated Roth contributions under qualified cash or deferred… IRCTreasury DecisionsFeb 6, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-7 Rev. Rul. 2006-7
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 February 2006.
T.D. 9238 T.D. 9238
Temporary and proposed regul…
IRCCourt RulingsJun 14, 2012related by meaning
_
requirements under section 6020(b) Wheeler v. Commissioner, 127 T.C. 200
208-209 (2006), aff'd, 521 F.3d 1289 (10th Cir. 2008). A return made by the Secretary under section 6020(b) is'treated as the return filed by the taxpayer for
purposes of section 6651(a)(2). Sec. 6651(g)(2). Respondent'satisfied his burden
by in…
U.S. Tax Court — Val Lanes Recreation Center Corporation v. Commissioner IRCCourt RulingsJun 26, 2018
…the initial °The Court bases its finding on the ESOT's Form 5500 for the plan year
ending March 31, 2001; the ESOT's Schedule K-1, Shareholder's Share of
Income, Credits, Deductions, etc., for petitioner for the period from October 1,
2000, to March 31, 2001; the ESOT's Schedule K-1 for Essy Management;
petitioner's Fo…
IRCCourt RulingsSep 22, 1998related by meaning
nerally presumed correct.
Rule 142(a); Welch v. Helvering
, 290 U.S. 111, 115 (1933).
Furthermore, every item of a person's gross income is subject to Federal income tax unless there is a statute or some rule of law
that exempts the person or the item from gross income. HCSC-
Laundry v. United States
, 450 U.S. 1, 5 (1…