IRCCourt RulingsApr 25, 1972related by meaning
ecision will ~be entered for the petitioners.
unless otherwise indicated, all section references are to the Internal Revenue Code of 1954, as amended. This date is at variance with the date shown on the acceptance, Dec. 31, 1963. However, the parties agree by stipulation that the application was accepted on Dec. 31, 19…
IRCCourt RulingsAug 29, 2006
Whether a Portion of the 2002 Distribution Was Taxed Twic e
Petitioner asserts tha t
received in Decembe r
contribution that he
of 2002
$3,500 of th e represents the amount of the IR A
distribution that h e
made earlier in the same year . He argue s
that he is taxed on the $3,500 as a . result of the distribution i n
D…
IRCCourt RulingsOct 31, 2007related by meaning
STAT .
T .C . Memo . 2007-327
UNITED STATES TAX COUR T
GREGORY EUGENE THOMPSON, Petitioner v .
COMMISSIONER OF INTERNAL REVENUE, Responden t
Docket No . 1182-06 .
Filed October 31, 2007 .
Gregory Eugene Thompson , pro se .
Douglas S . Polsky, for respondent .
MEMORANDUM OPINIO N
KROUPA, Judge : Respondent determined a …
85 FR 31884 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAFinal Rules (FR)May 27, 2020
ded ERISA's delivery standards in 2002 by establishing a safe harbor for the use of electronic media to furnish disclosures (the 2002 safe harbor).[3] The 2002 safe harbor was not and is not the exclusive means by which a plan administrator may use electronic media to satisfy the general standard. However, plan adminis…
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…
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 …
Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl… IRCRevenue RulingsMar 8, 2004
…001-10 sets forth certain additional conditions on the use of the insurer’s published rates. Notice 2002-8, 2002-1 C.B. 398, revokes Notice 2001-10. Under Notice 2002-8, Rev. Rul. 55-747 remains revoked; however, taxpayers can use the rates set forth in Rev. Rul. 55-747 for purposes of determining the value of current …
IRCCourt RulingsOct 3, 1995related by meaning
income tax return. Although
the Court can appreciate petitioners' frustration, we must
nevertheless note that matters involving interest do not, as a general rule, fall within the scope of this Court's jurisdiction.
Perkins v. Commissioner
, 92 T.C. 749, 752 (1989); LTV Corp. v.
Commissioner
, 64 T.C. 589, 597 (1975); …
Rev. Proc. 2003-86 — Professional employer organizations; employee leasing; plan qualification. This procedure describes certain transitional rules that may be used by defined cont… IRCRevenue ProceduresDec 15, 2003
…n certain transitional issues that were raised by practitioners after the publication of Rev. Proc. 2002-21.
SECTION 2. BACKGROUND .01 If a PEO satisfies the requirements under Rev. Proc. 2002-21, the Service will not disqualify the PEO Retirement Plan solely on the grounds that the plan has violated the exclusive bene…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026related by meaning
nnual period.
ACTION ON DECISION
Subject: Mohamed K. Abdo and Fardowsa J. Farah v. Commissioner, 162 T.C. 148 (April 2, 2024) (reviewed by the court). Issue: Whether the originally enacted version of 26 U.S.C. § 7508A(d)1 provided for an automatic and mandatory 60-day postponement of certain tax-related deadlines for a…
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…
IRCCourt RulingsApr 11, 2012
…ges listed on the census form were grossly overstated. .
In each of the years 1999, 2000, 2001, and 2002, Diogenes paid $200,000 to
the xélan 419 plan and the xélan 419 plan remitted equivalent payments to
Indianapolis Life. Diogenes paid xélan the $600 anmial administration fee to
participate in the xélan 419 plan dur…
IRCCourt RulingsJul 8, 2020related by meaning
s, including the experience, knowledge, and
education of the taxpayer." Ibid.
Petitioner prepared her 2016 return during a very tumultuous time in her life. We found credible her testimony that she attempted to report her tax liability
correctly. She reported the full amount of the IRA distributions she received
($54,5…
IRCCourt RulingsApr 25, 2011related by meaning
under section 72(t) for an early
distribution from a qualified retirement plan in 2005.'
'The 10-percent additional tax applies only to the TSP loans that petitioner failed to repay. Respondent did not assert in
(continued...)
- 11 -
IV. Conclusion
In summary, we conclude that (1) petitioner received taxable
disability…