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, 2003related by meaning
rders) applies for transfers, distributions, and payments made after December 31, 2001.
Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
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…
IRCCourt RulingsJun 25, 2012related by meaning
under section 72(t). Consistent with a prior determination regarding
the section 6015 relief, respondent also conceded that petitioner was entitled to allocate the portion of the 2008 Federal income tax liability attributable to the
unreported nonemployee compensation of $16,027 from FedEx to Mr. Scarlett
under section…
IRCCourt RulingsJun 26, 2017related by meaning
e requirements of the QDRO provisions must be "rigidly observed"
because they "relate to the substance or essence of the statute"). We have con-
- 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help
minimize stress on his soon-to-be ex-wife disabled him from satisfying the
statutor…
IRCCourt RulingsMar 31, 1997related by meaning
ort the 10-percent additional tax,
believing that he qualified for the disability exception.
Although petitioner failed to qualify under the technical provisions of the Internal Revenue Code and the regulations, we
- 13 -
do not believe petitioner acted unreasonably or intentionally
disregarded the rules and regulation…
Notice 2007-78 — This notice provides transition relief and additional guidance on the application of section 409A of the Code to nonqualified deferred compensation plans. The … IRCNoticesOct 9, 2007
…, a plan may provide, or be amended to provide, for new payment elections on or before December 31, 2007, with respect to both the time and form of payment of such amounts and the election or amendment will not be treated as a change in the time or form of payment under § 409A(a)(4) or an acceleration of a payment unde…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
B. 2026-01 143
2026-4 2026-01 I.R.B. 2026-01 160
2026-5 2026-01 I.R.B. 2026-01 258
2026-6 2026-02 I.R.B. 2026-02 314
2026-7 2026-02 I.R.B. 2026-02 316 2026-8 2026-04 I.R.B. 2026-04 380
2026-9 2026-04 I.R.B. 2026-04 393
2026-10 2026-04 I.R.B. 2026-04 394
2026-12 2026-07 I.R.B. 2026-07 535
2026-13 2026-09 I.R.B. 2026-09 …
IRCProposed Rules (FR)Proposed Oct 15, 2007
percentage (FTAP) for the 2007 plan year is limited to 110% of the fair market value of assets on January 1, 2007, or $1,100,000 (110% of $1,000,000). (iii) Pursuant to paragraph (j)(2)(iii)(B)(2) of this section, the funding standard account credit balance as of January 1, 2007, is subtracted from the asset value used…
IRCCourt RulingsSep 17, 2026related by meaning
n effect at all relevant times, regulation references are
to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure.
Served 09/17/26
2
[* 2 ] there were no changes in the IRS approach to the issue after review
of…
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 RulingsMar 23, 2009related by meaning
Rul . 2002-62, 2002-2 C .B . 710 ;, Notice
89-25, Q&A-12, 1989-1 C .B . 662, 666 .
7 -
Section 72(t)(4)4 provides that the-exception found in section 72(t)(2)(A)(iv) is not applicable if the series of substantially
equal periodic payments is subsequently modified (other than by
reason of death or disability) before th…
T.D. 9836 — These final regulations provide guidance regarding substantiation and reporting requirements for cash and noncash charitable contributions. The final regulatio… IRCTreasury DecisionsAug 13, 2018related by meaning
602.101 OMB Control numbers.
* * * * *
(b) * * *
______________________________________________________________
CFR part or section where Current OMB identified and described control No.
* * * * *
1.170A–15. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . .. . …
Rev. Rul. 2009-40 — 2010 covered compensation tables; permitted disparity. The covered compensation tables under section 401 of the Code for the year 2010 are provided for use in … IRCRevenue RulingsDec 28, 2009related by meaning
Rights II, the Internal Revenue Service Restructuring and Reform Act of 1998, and the American Jobs Creation Act of 2004.
REG-111833-99 REG-111833-99 Proposed regulations under section 7430 of the Code relate to awards of administrative costs and attorneys fees to conform the regulations to the amendments made in the …
REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie… IRCProposed Rules (FR)Proposed Jul 5, 2005
dditions represent the maximum allowable under section 415(c) and §1.415(c)-1. On July 15, 2007, F dies, and A inherits all of F’s stock in Z in 2007. (ii) As of July 15th 2007, A is considered to be in control of X and Z Corporations, and the two plans must be aggregated for purposes of applying the limitations of sec…
IRCCourt RulingsSep 3, 1998related by meaning
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
IRCCourt RulingsSep 19, 2016
ertain employees through the SICKNESS, ACCIDENT & DISABILITY
INDEMNITY TRUST 2007".
On December 31, 2007, Schechter signed an adoption agreement under which Simba Cal purported to adopt and agree to participate in the "Sickness,
Accident & Disability Indemnity Trust 2007". The adoption agreement identified
Schechter as…
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…
IRCCourt RulingsMar 25, 2013
…s
profit of $9,686,513; total income of $10,373,588; and taxable income of $41,948 on Form 1120 for 2007 (2007 Form 1120).
Petitioner paid a dividend to J. Lipsmeyer of $30,000 during each year in
issue. Petitioner paid compensation to J. Lipsmeyer and M. Lipsmeyer as officers.
- 7 -
[*7] Petitioner paid compensation t…