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61. Treas. Reg. § 1.401(a)(4)-11(g)(6) — Additional rules.
    IRCRegulationsMay 18, 2016
    … plan, the accrual rates for all HCEs (determined under the general test of § 1.401(a)(4)-3(c)) for 1998 are less than 1.5 percent of average annual compensation, and the accrual rates for all NHCEs (determined under the general test of § 1.401(a)(4)-3(c)) for 1998 are two percent of average annual compensation. If Emp…
62. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    ication of a pending or planned examination 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 effectiv…
63. PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsApr 23, 1999
    …g = Stock Holding 2 = State A = State B = Year 1 = This letter is in reply to a letter dated May 8, 1998, and supplemental correspondence, regarding the federal income tax consequences of a proposed transaction. Specifically, a ruling is requested that the conversion of a mutual insurance company to a stock insurance c…
64. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1996-556 UNITED STATES TAX COURT ALFRED P. DUFFY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6723-93. Filed December 23, 1996. Alfred P. Duffy, pro se. Judith Wilkie , for respondent. ME…
65. PLR 200148051 — Roth IRA
    IRCPrivate Letter RulingsNov 30, 2001
    vice issued an underreporter notice to the taxpayer for his 1998 year with the result that the 1998 modified AGI exceeded $100,000. The taxpayer filed an amended return for 1998, seeking a refund of the taxes paid on the Roth IRA conversion because there was a failed conversion. The taxpayer stated that he could not ta…
66. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
67. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002
    …delphia, Pennsylvania, on the date the petition was filed in this case. From January through May of 1998, petitioner was employed by the U.S. Defense Finance and Accounting Service. She earned $32,265 in this position, and was covered by her employer’s pension plan during that time. In May 1998, petitioner’s employment…
68. T.C. Summary Opinion 2002-14 — Armando Vega v. Commissioner
    IRCCourt RulingsFeb 15, 2002
    …tion of these issues into the IRA. A statement from Merrill Lynch for the period ending October 31, 1998, however, clearly shows that the distribution had been deposited into the CMA. During 1998, petitioner had a savings account with Hibernia National Bank. That account generated interest income of $117 that petitione…
69. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010related by meaning
    …ent,inniaking See Green'v . Commissioner , 507 F .3d 857, 868' (5th Cir . 2007)' - : affg' . T .C . Memo . 2005-250 ;- 10 - Stocks v . Commissioner, 98 .T .C . 1,_ 9 4(1992) "[T]he critical question is, in lieu of what was the settlement amount paid"?, Bagley v . Commissioner , 105 T .C ._ 396, 406 (1995) . ., affd . -…
70. T.C. Summary Opinion 2001-178 — Dennis J. Lawless v. Commissioner
    IRCCourt RulingsNov 28, 2001
    …an the amount shown on the taxpayer’s return. Sec. 301.6211-1(f), Proced. & Admin. Regs. On July 6, 1998, respondent abated the entire $7,219 assessment that he had previously made on May 25, 1998. Although the record is silent as to why respondent made this abatement, the fact that it was for the same amount as had be…