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61. T.C. Memo. 2011-31 — Scott Ray Holmes v. Commissioner
    IRCCourt RulingsFeb 1, 2011
    … filing separately, and one exemption, and he sought a refund of $8,593. Petitioner attached to the 2005 Form 1040 a Form 4852 reflecting zero wages for 2005. Petitioner wrote "Non assumpsit by" above his signature on the jurats of the Form 1040 and Form 4852. Petitioner also attached a 67-page document entitled "Notic…
62. T.D. 9447 — Final regulations under section 401 and other sections of the Code provide guidance relating to certain automatic contribution arrangements, eligible rollover …
    IRCTreasury DecisionsMar 23, 2009related by meaning
    on 414(w) for the entire plan year (or the portion of the plan year that the eligible NHCEs and eligible HCEs are eligible employees under the plan)). Qualified nonelective contributions and qualified matching contributions taken into account under §1.401(k)-2(a)(6) of this Chapter or qualified nonelective contribution…
63. Treas. Reg. § 1.424-1(e)(7) — Definitions and special rules applicable to statutory options.
    IRCRegulationsJan 19, 2017
    2005, and on or before June 1, 2006. On June 1, 2004, the fair market value of X Corporation's stock is $100 per share. On February 1, 2005, X Corporation modifies the option to provide that the option shall be exercisable on or before September 1, 2006. On February 1, 2005, the fair market value of X Corporation stock…
64. PLR 201927010 — Applicable Defined Benefit Plans
    IRCPrivate Letter RulingsJul 5, 2019
    …CSEC plan with respect to any given plan year, the plan must (1) have been in existence on July 26, 2005, (2) be a single plan mai ntained by more than one employer during the plan year that includes July 26, 2005 and each subsequent plan year through and including the plan year in question, and (3) satisfy the 85 perc…
65. T.C. Memo. 2001-9 — WSB Liquidating Corporation v. Commissioner
    IRCCourt RulingsJan 19, 2001related by meaning
    ated penalties. Accordingly, we sustain respondent’s determinations. To reflect the foregoing, Decision will be entered under Rule 155 with respect to the deficiencies, and for respondent with respect to the accuracy-related penalties .
66. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    red all of petitioners’ arguments for contrary holdings; those arguments not discussed herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent necessary to reject or sustain each determination . We also have considered all of respondent’s arguments a…
67. PLR 200728042 — Additional Income and Taxes Generated from the Backdating or Discounting of Exercised Stock Options
    IRCPrivate Letter RulingsJul 13, 2007
    …fore January 1, 2008, the applicable guidance under §409A (including transition guidance) is Notice 2005-1, 2005-1 CB 274, the preamble to the Proposed Regulations under §409A, 2005-2 CB 786 (70 FR 57930), and Notice 2006-79, 2006-43 IRB 763. For taxable years beginning before January 1, 2007, the guidance provides tha…
68. T.C. Memo. 2007-206 — Alex B. Rhodes, Jr. v. Commissioner
    IRCCourt RulingsJul 30, 2007related by meaning
    its own motion, impose a penalty of $15,000 on petitioner pursuant to section 6673(a)(1) . In reaching our holdings, we have considered all arguments made, and, to the extent not mentioned, we conclude that they are moot, irrelevant, or without merit . To reflect the foregoing, Decision will be entere d under Rule 155 …
69. Notice 2010-90 — This notice contains the 2010 Cumulative List of Changes in Plan Qualification Requirements (2010 Cumulative List) described in section 4 of Rev. Proc. 2007-44…
    IRCNoticesDec 27, 2010
    …(b)(3) of EGTRRA directed the Secretary of the Treasury to issue regulations under § 411(d)(6)(B). (2005 C. L.). Section 1.411(d)-3 of the Regulations was published on August 12, 2005 (70 Fed. Reg. 47109). (2005 C. L.). Amendments to § 1.411(d)-3 of the Final Regulations were published on August 9, 2006 (71 Fed. Reg. 4…
70. T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr…
    IRCTreasury DecisionsDec 9, 2013related by meaning
    of safe harbor matching contributions for plan years beginning on or after January 1, 2015. EMPLOYMENT TAX T.D. 9646 T.D. 9646 REG–146620–13T.D. 9646 Temporary and proposed regulations under section 3402(p)(3) relating to voluntary withholding agreements allow the Secretary to issue guidance in the Internal Revenue Bu…
71. 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…
72. T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409…
    IRCTreasury DecisionsJan 18, 2005
    … evasion of section 409(p). A public hearing on the proposed regulations is scheduled for April 20, 2005. REG–129709–03 REG–129709–03 Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409(p), identification of disq…
73. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    …d all Rule references are to the Tax Court Rules of Practice and Procedure. All (continued...) T.C. Memo. 2005-258 UNITED STATES TAX COURT JOYCE M. THOMAS, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10824-03. Filed November 1, 2005. Joyce M. Thomas, pro se. Andrew R. Moore , for respondent. …