T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (… IRCTreasury DecisionsMar 7, 2005related by meaning
Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified.
EXEMPT ORGANIZATIONS
T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
Notice 2008-112 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesDec 22, 2008
ginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
December 2008 4.66 4.19 4.89
MINIMUM PRESENT VALUE SEGMENT RATES Generally for plan years beginning after December 31, 2007, the applicable interest rates under § 417(e)(3)(D) are segment rates computed without regard to a 24-month av…
T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.… IRCTreasury DecisionsApr 30, 2007
dditions represent the maximum allowable under section 415(c) and §1.415(c)-1. On July 15, 2008, F dies, and A inherits all of F’s stock in Z in 2008. (ii) Conclusion. As of July 15, 2008, A is considered to be in control of X and Z Corporations, and the two plans must be aggregated for purposes of applying the limitat…
IRCCourt RulingsFeb 10, 2009related by meaning
ic v . ,Commissioner , T .C . Memo . 1992--
609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . .
In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her
medical condition
. She explained at trial that although she
received treatment from doctors in 2005, she did …
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…
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…
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 RulingsJul 15, 1997related by meaning
ntentional disregard of rules and
regulations." Additionally, they make no argument on brief
concerning the additions to tax pursuant to section 6653. Accordingly, we consider petitioners and the corporation to have
conceded the additions to tax pursuant to section 6653.
Petitioners and the corporation argue that, to t…
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…
T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner IRCCourt RulingsFeb 7, 2007related by meaning
…ur decisions to that effect. See Hansen v.
Commissioner
, 471 F.3d 1021 (9th Cir. 2006), affg. T.C. Memo. 2004-269; Mortensen v. Commissioner
, 440 F.3d 375 (6th Cir.
2006), affg. T.C. Memo. 2004-279; Van Scoten v. Commissioner
, 439
F.3d 1243 (10th Cir. 2006), affg. T.C. Memo. 2004-275.
Ms. Cochran testified that she …
Notice 2009-8 — This notice provides interim guidance on recently enacted section 457A of the Code which became effective January 1, 2009. Section 457A generally provides that… IRCNoticesJan 26, 2009
on of the Tax Extenders and Alternative Minimum Tax Relief Act of 2008, Div. C of Pub. L. No. 110-343 (TEAMTRA), which was enacted on October 3, 2008. This guidance is intended as interim guidance to assist taxpayers in applying § 457A while the Treasury Department and the IRS consider further guidance on the applicati…
Notice 2009-22 — Asset valuation under section 430(g)(3)(B) as amended by WRERA. This notice provides interim rules regarding asset valuation methods that are permitted to be u… IRCNoticesApr 6, 2009
…ate of return on plan assets for 2007, the assumed rate of return for 2007 is limited to 6.09%. For 2008, the third segment rate used to limit the assumed rate of return is the rate used for the January 1, 2008 valuation. Because the plan sponsor has elected to use the segment rates for the fourth month preceding the v…
IRCCourt RulingsJun 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
Notice 2024-55 — Certain Exceptions to the 10 Percent Additional Tax Under Code Section 72(t) IRCNoticesJul 8, 2024related by meaning
ent and the IRS will publish for public availability any comment submitted electronically or on paper to its public docket.
V. PAPERWORK REDUCTION ACT The collection of information contained in this notice has been submitted to the Office of Management and Budget in accordance with the Paperwork Reduction Act (PRA) (44…
IRCCourt RulingsJun 25, 2013related by meaning
T.C. Summary Opinion 2013-51
UNITED STATES TAX COURT
MARTIN TOOMBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27665-10S. Filed June 25, 2013.
James O. Creech III, for petitioner.
Thomas D. Yang, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
p…
IRCCourt RulingsApr 26, 2012related by meaning
…s. Constr. Co. v. United States, 695 F.2d
145, 148-149 (5th Cir. 1983); Kling v. Commissioner, T.C. Memo. 2001-78;
Seidenfeld v. Commissioner, T.C. Memo. 1995-61.
Tax Compliance Officer Alison Carillon (TCO) performed a bank deposit
analysis after she summonsed petitioners' bank records. Petitioners reported gross
rece…