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61. Treas. Reg. § 1.401(a)(4)-11(g)(6) — Additional rules.
    IRCRegulationsMay 18, 2016
    …assification test of § 1.410(b)-4. Because of attrition in the employee population in Division M in 1996, the group of employees to whom the right to direct investments is available during that plan year no longer meets the nondiscriminatory classification test of § 1.410(b)-4. Thus, the right to direct investments und…
62. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010related by meaning
    ibution from a retirement plan account ; and (4) whether petitioner is liable fo r an accuracy-related penalty pursuant to section 6662(a) . .2 When . he petitioned the Court, petitioner resided in Maryland . FINDINGS OF FAC T I . Petitioner's Settlement Proceed s For 28 years petitioner worked at Anne Arundel Medical …
63. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    other grounds, and remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206; Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 - II. Administrative Costs The administrative costs at issue are costs that petitioner incurred from the . time respondent issued the notice of deficiency up to the …
64. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    …he list of specific exceptions to tax set forth in section 72(t)(2). Swihart v. Commissioner , T.C. Memo. 1998-407. Moreover, unlike petitioners in the present case, the taxpayers in Larotonda never - 8 - received the funds and had no opportunity to avoid the 10-percent premature distribution penalty under former secti…
65. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …ubmitted four successive offers-incompromise (OIC): on June 5, 1997 (with respect to their 1995 and 1996 income tax liabilities); on November 4, 1997 (with respect to their 1995 and 1996 income tax liabilities); on April 6, 2004 (with respect to their 1995, 1996, 1999, 2000, 2001, and 2002 income tax liabilities); and …
66. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    …nial of equitable relief under the last sentence of section 66(c). Beck - 9 - v. Commissioner, T.C. Memo 2001-198. Here, we review respondent's denial of equitable relief under section 66(c) for abuse of discretion. Id ; see also Fernandez v. Commissioner, 114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…