IRCCourt RulingsApr 25, 2011related by meaning
(Including IRAs) and
Other Tax-Favored Accounts, petitione reported that the two TSP
loans she failed to repay, which tota.ed $11,496, were subject to the 10-percent additional tax but that the $12,000 distribution
was not subject to the 10-percent add tional tax because it was
due to total and permanent disability. Pe…
Notice 2011-97 — This notice contains the 2011 Cumulative List of Changes in Plan Qualification Requirements (2011 Cumulative List) described in section 4 of Rev. Proc. 2007-44… IRCNoticesDec 27, 2011
le performing qualified military service. (2010 C. L.)
Notice 2010-15, 2010-6 I.R.B. 390, provides guidance regarding HEART Act § 104(b). (2010 C. L.) Section 105(b)(1) of the HEART Act added § 414(u)(12) with respect to the treatment of differential wage payments during the period a person, while on active duty, is pe…
IRCCourt RulingsJan 20, 1983related by meaning
., automatic adjustments of the dollar limitations subject to the prohibition on advance funding of those adjustments by the language in dispute here. Petitioner argues that even if section 1.415-5(c)(l), Income Tax Regs., is held to be valid, which it is here, it should not apply to petitioner’s plan for the years in …
Notice 2010-24 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesMar 22, 2010
…Years Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
March 2010 4.39 3.95 4.61
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-mon…
Notice 2010-61 — Weighted average interest-rate update; corporate bond indices; 30-year Treasury securities; segment rates.This notice contains updates for the corporate bond w… IRCNoticesOct 4, 2010
…s Beginning in 30-Year Treasury Weighted Average Permissible Range
Month Year 90% to 105%
September 2010 4.30 3.87 4.52
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-mon…
IRCCourt RulingsFeb 26, 2014related by meaning
facts, the decision must rest on the facts." Id. at 121 (citing Dean v.
Commissioner, 57 T.C. 32, 44 (1971), Kaplan v. Commissioner, 21 T.C. 134, 140 (1953), Lanteen Med. Labs., Inc. v. Commissioner, 10 T.C. 279, 288 (1948), and
Elkins v. Commissioner, 12 B.T.A. 1058 (1928)).
Petitioners' case is not like Wood. The $3…
Notice 2010-78 — 2011 cost-of-living adjustments; retirements plans, etc. This notice sets forth certain cost-of-living adjustments effective January 1, 2011, applicable to the… IRCNoticesDec 6, 2010
…he cost-of-living indexes for the quarter ended Sept. 30, 2009, and for the quarter ended Sept. 30, 2010, were both less than the cost-of-living index for the quarter ended Sept. 30, 2008, and that the cost-of-living index for the quarter ended Sept. 30, 2010, is greater than the cost-of-living index for the quarter en…
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
the Code. Both sections 18 and 19 describe generally the effect of § 7805(b) relief.
Generally applied retroactively to modify or revoke prior TAM
.03 A holding that modifies or revokes a holding in a prior TAM is applied retroactively, with one exception. If the new holding is less favorable to the taxpayer than the e…
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014related by meaning
the Code. Both sections 18 and 19 describe generally the effect of §7805(b) relief.
Generally applied retroactively to modify or revoke prior TAM
.03 A holding that modifies or revokes a holding in a prior TAM is applied retroactively, with one exception. If the new holding is less favorable to the taxpayer than the e…
IRCCourt RulingsJul 13, 2015related by meaning
…etermined that petitioner is liable for an accuracy-related
penalty pursuant to section 6662(a) for 2010. Section 6662(a) provides a penalty
for an underpayment attributable to negligence or disregard of rules or regulations
within the meaning of section 6662(b)(1).
The Commissioner bears the burden of production regar…
IRCCourt RulingsAug 16, 2005related by meaning
2000-15, 2000-
(continued...)
actual knowledge of the factual basis for the 10-percent
additional tax pursuant to section 72(t), and he cannot rely on ignorance of the law for relief from liability. Mitchell v.
Commissioner
, 292 F.3d 800, 803-806 (D.C. Cir. 2002), affg. T.C.
Memo. 2000-332. Regardless of whether the t…
IRCCourt RulingsSep 10, 2015related by meaning
28
T.C. Memo. 2015-176
UNITED STATES TAX COURT
RONALD CRAIG FISH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10691-13. Filed September 10, 2015.
Ronald Craig Fish, pro se.
Joseph E. Nagy, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge: Respondent determined a $15,439 de…