IRCCourt RulingsJun 21, 2011related by meaning
…ess petitioner qualifies for an exception. See sec. 72(t) (1);
see also Stipe v. Commissioner, T.C. Memo. 2011-92; Dollander v.
Commissioner, T.C. Memo. 2009-187.
Petitioner has not alleged that any exception applies, nor
has he introduced any evidence that could allow us to conclude
that an exception applies. Therefor…
84 FR 56894 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAProposed Rules (FR)Proposed Oct 23, 2019
…ections 401(k)(13)(E) and 414(w)(4) for automatic contribution arrangements.
(iv) Technical Release 2011-03R On December 8, 2011, the Department issued Technical Release 2011-03R (TR 2011-03R), which sets forth an interim enforcement policy regarding the use of electronic media to satisfy the disclosure requirements un…
IRCCourt RulingsAug 1, 2012related by meaning
4, 2011, but was continued on petitioners' motion so that the parties
could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on
petitioners' motion so that they could take a trip out of the country.
By notice served May 9, 201…
Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013related by meaning
ed do not apply to requests for any documents to the extent § 6104 applies.
Statement identifying information to be deleted from public inspection
.04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
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…
IRCCourt RulingsDec 8, 2010related by meaning
iency on November 24,
2008. Pursuant to section 6503(a) (1), the mailing of the notice
of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records
- 8 -
"so long as the contents thereof may become material in the
administration of any internal revenue l…
IRCCourt RulingsJan 4, 2011related by meaning
…l tax- treatment-under section 501(a). See generally
Ronald R. Pawlak, P-.C. v. ,Commissioner, T.C. Memo. 1995-7
(discussing the types of preferential tax treatment:under section
501(a)). In addition, 'the Employee Retirement Income Security
Act of 1974, Pub. L. 93-406,- sec. 402(a) (1) 88 Stat. 875;
requires that the …
IRCCourt RulingsJul 8, 2020related by meaning
BD
T.C. Memo. 2020-101
UNITED STATES TAX COURT
TAMECCA SERIL, a.k.a. TAMECCA TILLARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4491-19. Filed July 8, 2020.
Tamecca Seril, a.k.a. Tamecca Tillard, pro se.
Marissa J. Savit and Thomas A. Deamus, for respondent.
MEMORANDUM FINDINGS OF FACT AND O…
IRCCourt RulingsJun 3, 1998related by meaning
…stituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a ruling
given to a specific taxpayer based upon the taxpayer's
specific facts and is not a ruling of general application.
See Golden Belt Tel. Association, Inc. v. Commissioner
, 108
T.C. 498, 506 (…
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 RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…
IRCCourt RulingsDec 29, 2005related by meaning
. ADM. ||
RVICE
STAT.
. . |S57-f JUDGE
' j FILES 042 t
T.C. Memo. 2005-298
UNITED STATES TAX COURT
ISABELLE BICHINDARITZ, Petitioner 1.
COMMISSIONER OF INTERNAL REVENUE, Respondént
Docket No. 16098-0.3. Filed December 29, 2005.
Scott A. Schumacher, for petitioner.
Catherine L. Campbell, for respondent.
MEMORANDUM FINDI…
IRCCourt RulingsJul 10, 2017related by meaning
09).
Petitioners concede that none of the exceptions in section 72(t)(2) applies with
respect to all or any portion of their retirement distribution.3 On the record before us, we find that petitioners are liable for their taxable
year 2008 for the 10-percent additional tax imposed by section 72(t)(1) with
respect to th…
IRCCourt RulingsJun 6, 2019related by meaning
ng a deficiency after issuing a
refund. McCree v. Commissioner, at *18-*20.
It is clear from our review of the record that SO Taylor verified that the requirements of any applicable law and administrative procedure were followed
- 20 -
[*20] and that in sustaining the proposed levy against petitioner, SO Taylor
properl…