Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to T.C. Memo. 2006-235 (not yet in the library — opens the official source)
85 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. PLR 200118016 — Notification of Secretary of Labor
    IRCPrivate Letter RulingsMay 4, 2001related by meaning
    …30-00/CC:TEGE:EB:QP1 UILC: 4975.07-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area Attn: Laura Beth Heisen FROM: Michael Roach, Chief CC:TEGE:EB:QP1 SUBJECT: Adequacy of Department of Labor Notification Pursuant to I.R.C. §4975(h)…
  2. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    …ion. Mr. Couturier filed his income tax returns for the years at issue on April 11, 2005, April 15, 2006, April 15, 2007, October 9, 2008, and April 15, 2009, respectively. The Commissioner issued the Notice on
  3. T.C. Memo. 2010-200 — Cheryl Elizabeth & Don Edward Hill v. Commissioner
    IRCCourt RulingsSep 13, 2010related by meaning
    … a matter which is within the discretion of the Commissioner . . Colvin v . . Commissioner , T .C . Memo . 2004-67, affd . 122 Fed . Appx . 788 (5th Cir . 2005) . Furthermore,petitioners have failed to identify a ministerial or managerial delay by an IRS employee that cause d ,them to forgo making payments on their . i…
  4. PLR 200820009 — Investment in Contract
    IRCPrivate Letter RulingsMay 16, 2008related by meaning
    Internal Revenue Service Department of the Treasury Washington, DC 20224 Number: 200820009 Release Date: 5/16/2008 Index Number: 72.02-00, 72.20-00, 401.0000, 401.06-00, 402.00-00, 403.00-00, 408.06-00, 4973.00-00, 4979.00-00 -------------------------- ------------------------------------------------------------ ------…
  5. T.C. Memo. 2013-245 — Terry L. & Sheila K. Ellis v. Commissioner
    IRCCourt RulingsOct 29, 2013
    … that had paid compensation to Mr. Ellis in 2005, was thus owned primarily by his IRA. II. Tax Year 2006 A. CST and CDJ Operations On January 1, 2006, CST entered into an agreement to lease the Harrisonville parcel from CDJ from January 1, 2006, to January 1, 2016. CST used this real estate to operate its used car busi…
  6. T.C. Memo. 2011-139 — Raymond H. & Ana A. Ryan v. Commissioner
    IRCCourt RulingsJun 21, 2011
    efore the loan was not a taxable distribution in 2003. On March 21, 2006, the Air Force removed petitioner from service and 'notified the TSP. The Air Force did not reinstate petitioner within 31 days from March 21, 2006. As a result, the TSP notified petitioner that the loan provisions required repayment of the outsta…
  7. T.C. Memo. 2016-55 — Brenda S. Jones v. Commissioner
    IRCCourt RulingsMar 28, 2016
    …Life insurance policy Year allocation accumulation value 2004 $88,237 $113,607 2005 111,763 204,135 2006 -0- 303,317 John Machacek was fully vested under the terms of the SBP in 2005 and 2006. In 2005 and 2006 he would have been entitled to a preretirement or postretirement death benefit of approximately $786,000.4 The…
  8. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
    IRCCourt RulingsAug 28, 2008related by meaning
    T .C . Memo . 2008-20 4 UNITED STATES TAX-COUR T WALTER KOWSH, Petitioner v . COMMISSIONER OF . INTERNAL . REVENUE, Responden t Docket No . 15154-06 . Filed August 28, 2008 . Walter Kowsh, pro se . Michelle L . Maniscalco , for respondent . MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N KROUPA, Judge : Respondent determined…
  9. T.C. Memo. 2007-206 — Alex B. Rhodes, Jr. v. Commissioner
    IRCCourt RulingsJul 30, 2007
    …d a penalty on petitioner of $2,000 under section 6673(a)(1) . See Rhodes v . Commissioner , T .C . Memo . 2003-133 ; affd . 152 Fed . Appx . 340 (5th Cir . 2005) . In the above-docketed case, the Court has warned - 7 - petitioner on six occasions of the possibility of imposing a penalty under section 6673(a)(1) if he …
  10. T.C. Memo. 2020-5 — Ed Thielking, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 2020
    …inently in prior cases before this Court. See Val Lanes Recreation Ctr. Corp. v. Commissioner, T.C. Memo. 2018-92; Churchill, Ltd. Emp. Stock Ownership Plan & Tr. v. Commissioner, T.C. Memo. 2012-300; Hollen v. Commissioner, T.C. Memo. 2011-2, aff'd per curiam, 437 F. App'x. 525 (8th Cir. 2011). This case involves an S…
  11. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007
    …’ “equitable facts” include reference to: (1) Petitioners’ reliance on Bales v. Commissioner , T.C. Memo. 1989568; 13 (2) petitioners’ reliance on Hoyt’s enrolled agent status; - 26 - 13 (...continued) Appeals for the Sixth, Ninth, and Tenth Circuits. See, e.g., Hansen v. Commissioner , 471 F.3d 1021 (9th Cir. 2006), a…
  12. 90 FR 3667 — Prohibited Transaction Exemption (PTE) 2002-51 To Permit Certain Transactions Identified in the Voluntary Fiduciary Correction Program
    ERISAFinal Rules (FR)Jan 15, 2025related by meaning
    an]. If the terms of the class exemption are met, [Insert Name of Applicant] will qualify for relief from the excise taxes that would otherwise apply. One of the requirements for excise tax relief is for [Insert Name of Applicant] to provide you with this notice so you have an opportunity to provide comments to EBSA ab…
  13. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    …ne who financially benefits from the transaction." Tigers Eye Trading, L.L.C. v. Commissioner, T.C. Memo. 2009-121 (citing Hansen v. Commissioner, 471 F.3d 1021, 1031 (9th Cir. 2006) (''a taxpayer cannot negate the negligence penalty through reliance on a transaction's promoters or on other advisors who have a conflict…
  14. 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 .
  15. T.C. Memo. 2013-45 — Alan R. & Toni A. Pinn v. Commissioner
    IRCCourt RulingsFeb 11, 2013
    …. See Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729 (1929); Sanders v. Commissioner, T.C. Memo. 2010-279, 2010 WL 5327897, at *2; McGowen v. Commissioner, T.C. Memo. 2009-285, 2009 WL 4797538, at *3-*5, aff'd, 438 Fed. Appx. 686 (10th Cir. 2011); Barr v. Commissioner, T.C. Memo. 2009-250, 2009 WL 3617587, at …
  16. 75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac…
    IRCFinal Rules (FR)Jul 6, 2010related by meaning
    …This section applies with respect to transactions entered into by a tax-exempt entity after May 17, 2006. § 301.6033-5T [Removed] Par. 14. Section 301.6033-5T is removed. PART 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 15. The authority citation for part 602 continues to read, in part, as follows: A…
  17. T.C. Memo. 2020-101 — Tamecca Seril a.k.a. Tamecca Tillard v. Commissioner
    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…
  18. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
  19. Treas. Reg. § 1.72(p)-1(b) — Loans treated as distributions.
    IRCRegulationsSep 17, 2024
    …n section 72(p)(2)(A). The amount of the new loan is $40,000, the outstanding balance on January 1, 2006, of the loan it replaces is $33,322, and the highest outstanding balance of loans from the plan during 2005 was $40,000. Accordingly, under section 72(p)(2)(A), the sum of the new loan and the outstanding balance on…
  20. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    …ceedings were commenced in the Circuit Court of Cook County, Illinois (family court).. -042 In July 2006 the family court entered a judgmeñt for dissolution of marriage (divorce decree) that incorporated a Maritál Settlement Agreement (MSA). The MSA was later amended by an agreed order.