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Go to T.C. Memo. 2013-186 (not yet in the library — opens the official source)
77 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    red all of petitioners’ arguments for contrary holdings; those arguments not discussed herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent necessary to reject or sustain each determination . We also have considered all of respondent’s arguments a…
  2. T.C. Memo. 2014-80 — Michael H. Boulware v. Commissioner
    IRCCourt RulingsMay 6, 2014
    …upon an opinion rendered by this Court on June 8, 2009, in HIE Holdings, Inc. v. Commissioner, T.C. Memo. 2009-130 (deficiency case), affirmed by the Court of Appeals for the Ninth Circuit on April 5, 2013, 521 Fed. 'All section references are to the Internal Revenue Code (Code) in effect at all relevant times, and all…
  3. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    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…
  4. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
  5. TR 2013-03 — Technical Release 2013-03
    ERISADOL Technical ReleasesSep 13, 2013
    …ge, unused amounts credited before January 1, 2014 consisting of amounts credited before January 1, 2013, and amounts that are credited in 2013 under the terms of an HRA as in effect on January 1, 2013, may be used after December 31, 2013 to reimburse medical expenses in accordance with those terms without causing the …
  6. 78 FR 48548 — Appraisals for Higher-Priced Mortgage Loans-Supplemental Proposal
    IRCProposed Rules (FR)Proposed Aug 8, 2013
    tten Appraisal to the consumer. 12 CFR 1026.35(c)(6). The requirements provided in the 2013 Final Rule were described in the PRA section of that rule. See78 FR 10368, 10429 (February 13, 2013). As described in its section 1022 analysis in the 2013 Final Rule and in Table 3 to that rule, the estimated burdens allocated …
  7. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    …le cause and good faith. Higbee v. Commissioner, 116 T.C. at 449 (citing Remy v. Commissioner, T.C. Memo. 1997-72). The many section 72(t) cases, just some of which have been cited supra pp. 7-8, strongly indicate a common misunderstanding among taxpayers that financial hardship is an exception to the section 72(t) add…
  8. 78 FR 218 — Shared Responsibility for Employers Regarding Health Coverage
    IRCProposed Rules (FR)Proposed Jan 2, 2013
    Section 4980H is effective for months beginning after December 31, 2013. Employers that intend to utilize the look-back measurement method for determining full-time status for 2014 will need to begin their measurement periods in 2013 to have corresponding stability periods for 2014. The Treasury Department and the IRS …
  9. T.C. Memo. 2010-200 — Cheryl Elizabeth & Don Edward Hill v. Commissioner
    IRCCourt RulingsSep 13, 2010related by meaning
    … a matter which is within the discretion of the Commissioner . . Colvin v . . Commissioner , T .C . Memo . 2004-67, affd . 122 Fed . Appx . 788 (5th Cir . 2005) . Furthermore,petitioners have failed to identify a ministerial or managerial delay by an IRS employee that cause d ,them to forgo making payments on their . i…
  10. T.C. Memo. 2022-101 — William T. Ashford v. Commissioner
    IRCCourt RulingsSep 29, 2022related by meaning
    cord from $83,093.00 to $0.00 for tax year 2013.” See § 6103( l )(1)(A) (“The Secretary may . . . disclose returns and return information with respect to . . . taxes imposed by chapters 2 [Tax on Self - Employment Income ], 21, and 24 , to the Social Security Administration for purposes of its administration of the Soc…
  11. T.C. Memo. 2021-105 — Sherrie L. Webb v. Commissioner
    IRCCourt RulingsAug 31, 2021related by meaning
    including granting CNC status - - s ince petitioner did not furnish necessary documentation. On the basis of these circumstances M s. Rego performed a balancing test, concluding that the proposed levy did balance the needs of collection with the concerns of petitioner. On the basis of our review w e hold that M s. Rego…
  12. Notice 2014-8 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in January 2014; the 24 month average segment rates…
    IRCNoticesJan 27, 2014
    …ng target. Pursuant to Notice 2007–81, the monthly corporate bond yield curve derived from December 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of December 2013 are, respectively, 1.25, 4.57, and 5.60. For plan years beginning on or after January 1, 2…
  13. T.C. Summary Opinion 2020-5 — Tracey Rene Merrell & Christopher L. Merrell v. Commissioner
    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…
  14. 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 (…
  15. T. C. Memo. 2011-267 — Benny Nipps v. Commissioner
    IRCCourt RulingsNov 10, 2011related by meaning
    understanding of the law. In reaching the foregoing holdings, the Court has considered the parties' arguments, and, to the extÈnt not ddressed herein, concludes that they are moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered under Rule 155.
  16. Notice 2013-6 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesMar 4, 2013
    …g in 2012, the three adjusted 24-month average corporate bond segment rates applicable for February 2013, taking into account the applicable percentage of the 25-year average segment rates, are as follows: Adjusted 24-Month Average Segment Rates, Using Applicable Percentage of 25-Year Average Segment Rates Applicable M…
  17. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    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…