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 RulingsMay 23, 2005related by meaning
…herwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2001,
the taxable year in issue. All monetary amounts are rounded to
the nearest dollar.
T.C. Summary Opinion 2005-62
UNITED STATES TAX COURT
THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v
.
COMMISSIONER OF IN…
Rev. Proc. 2010-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 4, 2010
…mation letters, etc.: See Rev. Proc. 2010-4, page , this Bulletin.
(2) M&P and VS plans: See Notice 2001-42, 2001-2 C.B. 70, Notice 2001-57, 2001-2 C.B. 279, Rev. Proc. 2001-55, 2001-2 C.B. 552, Rev. Proc. 2002-29, 2002-1 C.B. 1176 (as modified by Rev. Proc. 2003-10, 2003-1 C.B. 259), Rev. Proc. 2002-73, 2002-2 C.B. 93…
Rev. Proc. 2009-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 5, 2009
…mation letters, etc.: See Rev. Proc. 2009-4, page , this Bulletin.
(2) M&P and VS plans: See Notice 2001-42, 2001-2 C.B. 70, Notice 2001-57, 2001-2 C.B. 279, Rev. Proc. 2001-55, 2001-2 C.B. 552, Rev. Proc. 2002-29, 2002-1 C.B. 1176 (as modified by Rev. Proc. 2003-10, 2003-1 C.B. 259), Rev. Proc. 2002-73, 2002-2 C.B. 93…
IRCCourt RulingsJun 4, 2014related by meaning
hey would establish that respondent proceeded against the targets using
information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's
award determination.
We hold, consistent with the rationale of Dacosta, that this Court…
Rev. Proc. 2008-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 7, 2008
…mation letters, etc.: See Rev. Proc. 2008-4, page , this Bulletin.
(2) M&P and VS plans: See Notice 2001-42, 2001-2 C.B. 70, Notice 2001-57, 2001-2 C.B. 279, Rev. Proc. 2001-55, 2001-2 C.B. 552, Rev. Proc. 2002-29, 2002-1 C.B. 1176 (as modified by Rev. Proc. 2003-10, 2003-1 C.B. 259), Rev. Proc. 2002-73, 2002-2 C.B. 93…
Notice 2008-108 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the… IRCNoticesDec 15, 2008
…o § 1.401(a)(4)-8 of the Regulations relating to new comparability plans were published on June 29, 2001 (66 Fed. Reg. 34535). (2004 C. L.).
Rev. Rul. 2001-30, 2001-2 C.B. 46. (2004 C. L.).
Amendments to § 1.401(a)(4)-9 of the Regulations relating to new comparability plans were published on June 29, 2001 (66 Fed. Reg.…
Rev. Proc. 2007-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 2, 2007
…mation letters, etc.: See Rev. Proc. 2007-4, page , this Bulletin.
(2) M&P and VS plans: See Notice 2001-42, 2001-2 C.B. 70, Notice 2001-57, 2001-2 C.B. 279, Rev. Proc. 2001-55, 2001-2 C.B. 552, Rev. Proc. 2002-29, 2002-1 C.B. 1176 (as modified by Rev. Proc. 2003-10, 2003-1 C.B. 259), Rev. Proc. 2002-73, 2002-2 C.B. 93…
IRCCourt RulingsNov 7, 2003related by meaning
1
Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year at issue.
T.C. Summary Opinion 2003-161
UNITED STATES TAX COURT
MARTIN EDWARD CAULFIELD, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19485-02S. Filed November 7, 2003.
Martin Ed…
T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.… IRCTreasury DecisionsApr 30, 2007
…ation of a defined benefit plan and a defined contribution plan under former section 415(e). Notice 2001-37, 2001-1 C.B. 1340, (see §601.601(d)(2)) provides guidance regarding the inclusion of salary reduction amounts for qualified transportation fringe benefits in the definition of compensation for purposes of section…
Rev. Proc. 2006-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 3, 2006
…mation letters, etc.: See Rev. Proc. 2006-4, page , this Bulletin.
(2) M&P and VS plans: See Notice 2001-42, 2001-2 C.B. 70, Notice 2001-57, 2001-2 C.B. 279, Rev. Proc. 2001-55, 2001-2 C.B. 552, Rev. Proc. 2002-29, 2002-1 C.B. 1176 (as modified by Rev. Proc. 2003-10, 2003-1 C.B. 259), Rev. Proc. 2002-73, 2002-2 C.B. 93…
Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul… IRCNoticesDec 27, 2005
…o § 1.401(a)(4)-8 of the Regulations relating to new comparability plans were published on June 29, 2001 (66 Fed. Reg. 34535).
Rev. Rul. 2001-30, 2001-2 C.B. 46.
Amendments to § 1.401(a)(4)-9 of the Regulations relating to new comparability plans were published on June 29, 2001 (66 Fed. Reg. 34535). (New).
Rev. Rul. 20…
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…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003
…ed in this section, §§1.457-1 through 1.457-11 apply for taxable years beginning after December 31, 2001. (b) Transition period for eligible plans to comply with EGTRRA. For taxable years beginning after December 31, 2001, and before January 1, 2004, a plan does not fail to be an eligible plan as a result of requiremen…
IRCCourt RulingsMar 25, 2013
…yees in deciding whether compensation is reasonable. See Wagner Constr.,
Inc. v. Commissioner, T.C. Memo. 2001-160. This factor focuses on whether the
entity pays top dollar to all of its employees, including both shareholders and
nonshareholders. Wagner Constr., Inc. v. Commissioner, T.C. Memo. 2001-160;
Eberl's Claim…
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 …
IRCCourt RulingsJul 8, 2020related by meaning
pplied to the IRS. On September 17, 2018, the AUR unit sent petitioner a
Notice CP2000 indicating that she (1) had failed to report $15,000 of taxable distributions, (2) had underreported the 10% additional tax due, and (3) was
subject to an accuracy-related penalty. The letter instructed her to file a response
by Octo…
IRCCourt RulingsApr 11, 2012
…ported the following relevant amounts on their jointly filed Federal individual income tax returns:
2001 2002 2003
Gross income $1,418,560 $1,115,707 $1,142,511
Itemized deductions 122,512 110,429 27,462
Taxable income (loss) 1,296,048 1,005,278 1,115,049
Income tax 478,797 358,773 350,805
Brownsville Medical reported …
IRCCourt RulingsSep 28, 2016
…o argument as to why it does not. It appears that Conseco
appropriately used the IRS-provided Table 2001 to arrive at the correct premium
- 15 - [*15] rate, despite the worksheets' references to "PS-58" headings. (Premium
factors provided by P.S. 58 rates, found in Rev. Rul. 55-747, 1955-2 C.B. 228,
229, have generally…