IRCCourt RulingsJun 10, 1957related by meaning
OPINION.
Rev. Proc. 2007-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 2, 2007
…mation letters, etc.: See Rev. Proc. 2007-4, page , this Bulletin.
(2) M&P and VS plans: See Notice 2001-42, 2001-2 C.B. 70, Notice 2001-57, 2001-2 C.B. 279, Rev. Proc. 2001-55, 2001-2 C.B. 552, Rev. Proc. 2002-29, 2002-1 C.B. 1176 (as modified by Rev. Proc. 2003-10, 2003-1 C.B. 259), Rev. Proc. 2002-73, 2002-2 C.B. 93…
IRCCourt RulingsDec 15, 2008related by meaning
…er’s determination of a deficiency in her 1993 and 1994 taxes. She lost, for reasons
explained in a summary opinion. The Commissioner came to
collect, and she demanded a collection due process hearing. The
Commissioner argued that she was barred from again challenging
her underlying liability at the hearing, but she th…
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
…ation of a defined benefit plan and a defined contribution plan under former section 415(e). Notice 2001-37, 2001-1 C.B. 1340, (see §601.601(d)(2)) provides guidance regarding the inclusion of salary reduction amounts for qualified transportation fringe benefits in the definition of compensation for purposes of section…
Rev. Proc. 2006-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section… IRCRevenue ProceduresSuperseded Jan 3, 2006
…mation letters, etc.: See Rev. Proc. 2006-4, page , this Bulletin.
(2) M&P and VS plans: See Notice 2001-42, 2001-2 C.B. 70, Notice 2001-57, 2001-2 C.B. 279, Rev. Proc. 2001-55, 2001-2 C.B. 552, Rev. Proc. 2002-29, 2002-1 C.B. 1176 (as modified by Rev. Proc. 2003-10, 2003-1 C.B. 259), Rev. Proc. 2002-73, 2002-2 C.B. 93…
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…
Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul… IRCNoticesDec 27, 2005
…o § 1.401(a)(4)-8 of the Regulations relating to new comparability plans were published on June 29, 2001 (66 Fed. Reg. 34535).
Rev. Rul. 2001-30, 2001-2 C.B. 46.
Amendments to § 1.401(a)(4)-9 of the Regulations relating to new comparability plans were published on June 29, 2001 (66 Fed. Reg. 34535). (New).
Rev. Rul. 20…
IRCCourt RulingsFeb 7, 2013related by meaning
ner, the taxpayer must demonstrate that the Commissioner's deficiency
assessment lacks a rational foundation or is arbitrary and excessive. Tinsman v. Commissioner, T.C. Memo. 2000-55.
- 8 -
Section 61(a) includes in gross income all income from whatever source
derived, including, but not limited to, interest. Sec. 61(…
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003
…ed in this section, §§1.457-1 through 1.457-11 apply for taxable years beginning after December 31, 2001. (b) Transition period for eligible plans to comply with EGTRRA. For taxable years beginning after December 31, 2001, and before January 1, 2004, a plan does not fail to be an eligible plan as a result of requiremen…
66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner IRCCourt RulingsMay 26, 1976related by meaning
butions.
All section references are to the Internal Revenue Code of 1954, as amended and in effect during the years in issue, unless otherwise stated. Sec. 131(c), I.R.C. 1939; sec. 905(c), I.R.C. 1954.
8 The fact that the Board made specific findings of the rates of exchange in effect at the date of accrual and at the…
IRCCourt RulingsJan 26, 2006
…whether the payments were applied
to more than one loan. Further, to the extent there was a loan in 2001, the terms of the loan and the record of repayments are
not made part of the record.
In 2001, CIG was acquired by Eagle Global Logistics (Eagle).
Petitioner was employed by Eagle after the merger and remained an
emp…
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 RulingsJun 8, 2005
her at Jordan Middle
School in August 2001, and she obtained her teaching credentials
in elementary education in April 2002. Currently, Mrs. Kandil is a sixth-grade teacher of math and science at Jordan Middle
School.
During the high-tech bubble in 2000, Mr. El-Bibany worked in
“some nonemployment type of activities” r…
IRCCourt RulingsNov 1, 2007
…ual Retirement Account (IRA) .
Background
For purposes of addressing the parties' cross-motions for
summary judgment, the record in this matter consists of the
pleadings, the parties' cross-motions for summary judgment, and
the relevant documents attached thereto . The underlying facts in
this case are not in dispute .…
IRCCourt RulingsMay 29, 1997related by meaning
urge us to adopt a
"rule of decisions", applicable in cases that are eligible for
small tax procedure, precluding the Commissioner from challenging
5 a taxpayer's treatment of an item if the Commissioner
"acquiesced" with respect to such treatment in prior years. See
sec. 7463. Respondent counters that the IRA deductio…
IRCCourt RulingsOct 4, 2012
…must be included in income under section 402(b)(4)(A) for 2004. Both parties
have moved for partial summary judgment with respect to that issue.
Petitioners argue that only the annual increase in petitioner husband's
vested accrued benefit for 2004 is includible in petitioners' income for that same
year under section 4…
73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner IRCCourt RulingsJan 31, 1980related by meaning
is v. Commissioner, 63 T.C. 11, 17 (1974) (compliance with requirements set forth in section 401(a)(6) rather than good faith intentions controlling). Closely related to this second argument is petitioner’s criticism of what it terms respondent’s “mindless devotion to hypertechnicality” or “monstrous pursuit of the pic…
PLR 200208017 — Taxation of Employee Annuities (Taxable v. Not Taxable) IRCPrivate Letter RulingsFeb 22, 2002
…4
Person to Contact:
Telephone Number:
Refer Reply To:
CC:CORP:B06-PLR-139821-01
Date:
November 23, 2001
Legend
Company =
Mutual Holding =
Stock Holding =
Subsidiary 1 =
State X =
State Y =
Year A =
Year B =
Year C =
Agreement X =
Date A =
Date B =
Date C =
2
PLR-139821-01
Date D =
Business A =
Business B =
Business C …
IRCCourt RulingsApr 2, 2020related by meaning
e conditions named in section 6404(e)(1) are met. The word "may"
- 18 -
[*18] signifies that Congress has conferred discretion on the Secretary of the Treasury. C[ Porter v. Commissioner, 132 T.C. 203, 206-208 (2009), abrogating
Butler v. Commissioner, 114 T.C. 276 (2000); see also id. at 237-238 (Gustafson,
J., dissen…
IRCPrivate Letter RulingsJul 19, 2002
…trust under
section 402(b) of the Code.
This ruling applies only to the Trust submitted on July 19, 2001 and amended in
accordance with the revision submitted on September 21, 2001 and to the Plan
submitted on July, 19, 2001. It is directed only to the taxpayer who requested it.
Section 6110(k)(3) of the Code provides …