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. 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 Proc. 2000-20 modified and superseded.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…
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…
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 …
IRCCourt RulingsJan 16, 2020related by meaning
…tirement account. See Arnold v. Commissioner, 111 T.C.
250, 255 (1998); Adams v. Commissioner, T.C. Memo. 2015-162, at *8;
Dollander v. Commissioner, T.C. Memo. 2009-187. The Court may not add an
exception to the Code by judicial fiat, and we are obliged to apply the law as
written. See Iselin v. United States, 270 U.S…
IRCCourt RulingsJul 13, 2010related by meaning
…t is too late .for, the taxpayer to elect joint
filing status . . Brattin v . Commissioner , r .C . Memo . 1992-625
(citing Thompson v . Commissioner , 78 T .C . 558, 561 (1982), an d
Phillips v . Commissioner , 86 T .C . 433, 441 n . :7 : (1986), affd . as
to this issue 851 F .2d 1492 (D .C : Cir . .1988))` .
16
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 RulingsJun 4, 2014
nondiscretionary whistleblower award claims in early 2008. See Notice 2008-4,
2008-1 C.B. 253. Whistleblowers seeking an award must fully complete and submit a Form 211. E sec. 3.02, 2008-1 C.B. at 254. The Whistleblower Office
will acknowledge receipt of the claim in writing. E sec. 3.05, 2008-1 C.B. at 255.
The Whist…
IRCCourt RulingsJan 26, 1984related by meaning
shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
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
e use of the SCC and suggested that the Department should allow self-correctors to choose whether (a) to provide notice to interested persons (but
not to EBSA) or (b) make the plan contribution. After considering these comments, the Department has not made this change. Self-correctors have a streamlined procedure for s…
IRCCourt RulingsNov 30, 2006related by meaning
…rewrite the law. See, e.g., Hildebrand v. Commissioner
, 683
F.2d 57, 59 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Johnson v.
Commissioner
, 661 F.2d 53, 54-55 (5th Cir. 1981), affg. 74 T.C.
1057 (1980). We must conclude that petitioner was, for Internal
Revenue Code purposes, an active participant in Inova’s
retireme…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
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…
IRCCourt RulingsDec 2, 2010related by meaning
55 years old.
- 16 -
She testified that the reason she withdrew the money was that she
needed it for "some major expense or something it required." At no time has petitioner contended that any of the exceptions set
forth in section 72(t) (2) are applicable to her circumstance, nor
has she explained why she believed the…
IRCCourt RulingsApr 25, 2011related by meaning
…ucing activity. See, e.g., Pittman v. Commissioner,
100 F.3d 1308, 1313 (7th Cir. 1996), affg. T.C. Memo. 1995-243;
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…
T.D. 9294 — Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recip… IRCTreasury DecisionsNov 27, 2006related by meaning
vide an applicable notice or to make a participant election merely because the notice or election was not in writing or written form.
Special Analyses It has been determined that this Treasury Decision is not a significant regulatory action as defined in Executive Order 12866. Therefore a regulatory assessment is not r…
IRCCourt RulingsMar 1, 2016related by meaning
ion provisions allow for the correction of an error made in a
closed tax year by extending the limitations period up to one year from the date a
- 8 - [*8] final determination is made. Secs. 1311, 1314(b); see Beaudry Motor Co. v.
United States, 98 F.3d 1167, 1168 (9th Cir. 1996). Their intent is to take "the
profit ou…