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Go to T.C. Memo. 2007-177 (not yet in the library — opens the official source)
77 documents · 0.30sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    treated as a gift, dividend, contribution of capital, payment of compensation, or other payment depending on the substance of the transaction. Section 7872 applies to a transaction that is a loan subject to a belowmarket interest rate and is described in one of several enumerated categories. Sec. 7872(c) (1), (e) (1), …
  2. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007related by meaning
    2003 letter to the Department of the Treasury, that she wants a citation for the law which makes her liable to pay Federal income tax. Petitioner did not cooperate with respondent to prepare this case for trial. Petitioner’s actions evidence an intention to delay the proceedings, and her arguments are frivolous and wit…
  3. T.C. Summary Opinion 2014-17 — Rebecca Smackey Hurd v. Commissioner
    IRCCourt RulingsFeb 25, 2014related by meaning
    for the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure. 2We round all monetary amounts to the nearest dollar. 3In the notice of deficiency respondent determined that petitioner had not included interest income of $17 in her 2008 taxable income. The parties have stipulated that p…
  4. 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…
  5. REG-113891-07 — Part IV. Items of General Interest
    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…
  6. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025related by meaning
    Treas. Reg. § 1.482-7T(i)(6) does not operate as a safe harbor and therefore does not preclude R from making a PCT allocation under paragraph (i)(3). 6. Held, further, R did not abuse his discretion under I.R.C. § 482 by adjusting P’s and S’s RAB shares to determine the required CST p ayment. 7. Held, further, R ’s me…
  7. 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 …
  8. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    …nial of equitable relief under the last sentence of section 66(c). Beck - 9 - v. Commissioner, T.C. Memo 2001-198. Here, we review respondent's denial of equitable relief under section 66(c) for abuse of discretion. Id ; see also Fernandez v. Commissioner, 114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
  9. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
  10. 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…
  11. T.C. Memo. 2012-344 — Karl E. Cross v. Commissioner
    IRCCourt RulingsDec 13, 2012related by meaning
    CLC T.C. Memo. 2012-344 UNITED STATES TAX COURT KARL E. CROSS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6009-09. Filed December 13, 2012. Mitchell Stuart Fuerst and Joseph A. DiRuzzo III, for petitioner. Brian E. Derdowski, Jr., and Carroll De Groff Lansdell, for respondent. MEMORANDUM OPIN…
  12. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    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); …
  13. 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…
  14. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017related by meaning
    to the January 2007 letter and that the representations in the court filing were true, we conclude that this information was not new information that could give this Court jurisdiction to consider his claim. The letter's primary purpose was requesting a payout based on "the materiality of the submissions * * * previous…
  15. T.C. Memo. 2016-174 — Jay D. Schechter v. Commissioner
    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…
  16. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
    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…
  17. T.C. Memo. 2023-141 — Danielle Monique Scott v. Commissioner
    IRCCourt RulingsNov 28, 2023related by meaning
    tion she received in 2019. ” Petitioner did not respond t o our Order by the October 2, 2023, deadline or subsequently. Discussion I. Summary Judgment The purpose of summary judgment is to expedite litigation and avoid costly, time-consuming, and unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (…