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61. Rev. Proc. 2004-15 — Minimum funding standards; waivers; notice. This procedure sets forth guidelines for requesting waivers of the minimum funding standards with respect to define…
    IRCRevenue ProceduresFeb 17, 2004
    …nces, preliminary conferences may be afforded in addition to conferences available under Rev. Proc. 2004-4, 2004-1 I.R.B. 125. SECTION 6. BANKRUPTCY PETITIONS If the applicant or a significant number of controlled group members file a bankruptcy petition after the request for a waiver of the minimum funding standard is…
62. T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a …
    IRCTreasury DecisionsMay 7, 2007related by meaning
    INCOME TAX Rev. Rul. 2007-29 Rev. Rul. 2007-29 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 May 2007. Announcement 2007-44 Announcement 2007-44 This anno…
63. T.C. Memo. 2010-200 — Cheryl Elizabeth & Don Edward Hill v. Commissioner
    IRCCourt RulingsSep 13, 2010
    Memo . 1997-331 ; Speer v . Commissioner Memo . 1993- 5 The fol accuracy of appears exce amount of ti (2) the Geor during 2004 . Further petitioner c T .C . Memo . 1996-323 ; Goshorn v . Commissioner , T .C . 1 8 . owing factors further diminish the credibility and etitioner's claim : (1) The number of hours claimed ~…
64. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
65. 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 …
66. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    oner , T .C . Memo . 2004-125 . - 6 - Petitioner has not argued, and she has failed to demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right . Consequently, we must uphold TRHCA section 408 if it bears a rational relationship to a legitimate govern…
67. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    … "supposed to make any other assessments [of tax] for that year." The examination of the Goldbergs' 2004 tax year could yield deficiencies and additions to tax, which would in turn lead to assessments of tax. If the IRS accepted Goldberg's pending offer-in-compromise while the 2004 examination was still taking place, t…
68. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    ng warned by the Court and after having received notice from the Court in a prior case. 6 On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's position is both frivolous and groundless. Accordingly, we exercise our discretion and award a penalty t…
69. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
70. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    v. Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo. 2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v. - 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001). While we acknowledge and are sympathetic to petitioner's financial straits, we have no aut…
71. T.C. Summary Opinion 2007-180 — Suzanne E. Barrera, a.k.a. Suzanne E. Battle v. Commissioner
    IRCCourt RulingsOct 24, 2007
    …eturn. See, e.g., Hopkins v. Commissioner , 121 T.C. 73, 88-89 (2003); Knorr v. Commissioner , T.C. Memo. 2004-212; Morello v. Commissioner , T.C. Memo. 2004-181; Keitz v. Commissioner , T.C. Memo. 2004-74; Ogonoski v. - 35 - Commissioner , T.C. Memo. 2004-52; Wiest v. Commissioner , T.C. Memo. 2003-91; see also Rev. P…
72. T.C. Memo. 2021-105 — Sherrie L. Webb v. Commissioner
    IRCCourt RulingsAug 31, 2021related by meaning
    including granting CNC status - - s ince petitioner did not furnish necessary documentation. On the basis of these circumstances M s. Rego performed a balancing test, concluding that the proposed levy did balance the needs of collection with the concerns of petitioner. On the basis of our review w e hold that M s. Rego…
73. 132 T.C. No. 15 — Gregory T. & Kim D. Benz v. Commissioner
    IRCCourt RulingsMay 11, 2009
    …ry 1 5 each year for a period based on petitioner wife's life expectancy . On or-before January 15, 2004, petitioner wife received a $102,311 .50 distribution from her IRA in accordance with-her election to receive a series of-substantially equal periodic payments . During 2004 petitioner wife received two additional d…
74. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    to the additional tax under section 72(t) and distinguished Larotonda and Murillo on the ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is equally true of the distribution here. - 5 - To reflect the foregoing, An appropriate order of dismissal a…
75. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
76. T.C. Memo. 2006-95 — Theodus J. Jordan v. Commissioner
    IRCCourt RulingsMay 8, 2006related by meaning
    002, it could not have been determined whether petitioner had any overpayment with respect to taxable year 2002. petitioner’s overpayment for 2001. 10 The disallowance of the credit that petitioner claimed with respect to this item does not affect the amount of petitioner’s deficiency for 2002. See sec. 6211(a) (defini…
77. Rev. Proc. 2005-25 — Fair market value; distributions; qualified retirement plans. This procedure provides guidance, including examples, of how fair market value may be determined …
    IRCRevenue ProceduresApr 25, 2005
    …evenue procedure applies to distributions, sales, and other transfers made on or after February 13, 2004, to permanent benefits within the meaning of § 1.79-0 provided on or after February 13, 2004, and to non-exempt employees’ trusts under § 402(b) for periods on or after February 13, 2004. However, for periods before…