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61. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ounting method involving only one of the items or sub-methods. (4) The tax effect of any transaction to be consummated at some indefinite future time. (5) Any matter dealing with the question of whether property is held primarily for sale to customers in the ordinary course of a trade or business. (6) The tax effect of…
62. T.C. Memo. 2015-178 — Gary Wayne Rodrigues v. Commissioner
    IRCCourt RulingsSep 10, 2015related by meaning
    collection alternative during the course of the CDP hearing. Furthermore, Settlement Officer Owyang determined that the requirements of applicable law and administrative procedure were met and concluded that sustaining the NFTL appropriately balanced the need for efficient collection of taxes with petitioner's concerns…
63. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    f section 6501, 1 section 6651(a)(1), 2 - 37 - 2 (...continued) (2003) ; Janpol v. Commissioner , 102 T.C. 499, 503, 505 (1994); Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, aff…
64. Notice 2013-2 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesFeb 4, 2013
    …Segment Rates First Segment Second Segment Third Segment 1.62 4.40 5.45 For plan years beginning in 2012, the 24-month average segment rates determined under § 430(h)(2)(C)(iv) must be not less than 90% nor greater than 110% of the 25-year average segment rates. Pursuant to Notice 2012-55, 2012-36 I.R.B. 332, the first…
65. T.C. Summary Opinion 2003-137 — John & Michele McGovern v. Commissioner
    IRCCourt RulingsSep 30, 2003related by meaning
    ance with its substance.” Neonatology Associates, P.A. v. Commissioner , 299 F.3d 221, 230 n.12 (3d Cir. 2002), affg. 115 T.C. 43 (2000). However, the Supreme Court “has observed repeatedly that, while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax co…
66. T.C. Summary Opinion 2012-11 — Tao Xu v. Commissioner
    IRCCourt RulingsJan 31, 2012related by meaning
    for Cai's benefit to be deductible, the recipient IRA would had to have been an IRA owned by Cai, not one owned by Xu with Cai merely the beneficiary. With respect to Xu's other contentions, we point out the longstanding maxim that ignorance of the law is no excuse for failure to comply with it. Sm eg, United States v.…
67. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    he extent not discussed above, we conclude those arguments are irrelevant, moot, or without merit. To reflect the foregoing, Decisions will be entered under Rule 155.
68. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    … Subs. v. Commissioner , 145 T.C. at 112 (quoting Sherley v. Sebelius, 689 F.3d 776, 784 (D.C. Cir. 2012) ). 208 To the extent it matters whether the Treasury Department considered the public comments, petitioner has conceded that the Treasury Department considered the public comments. First, paragraph 116 of the stipu…
69. T.C. Memo. 2019-145 — Jane M. Lassek, Petitioner and Michael E. Smith, Intervenor v. Commissioner
    IRCCourt RulingsOct 28, 2019
    …collection action. Petitioner concedes that she is liable for the overreported income tax withheld. 2012 Underpayment In 2012 petitioner took an $11,000 taxable distribution from her section 401(k) retirement plan account, and intervenor took a $23,510 distribution from his section 401(k) retirement plan account, $23,4…
70. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    … to prove that there exist no genuine issues of material fact and that they are entitled to partial summary judgment as a matter of law. Petitioners argue that the questions on the Form 5500 series returns do not elicit disclosure of amounts originally advanced in years prior to the year for which the return is filed. …
71. 79 FR 10296 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act
    IRCFinal Rules (FR)Feb 24, 2014
    …(3)(iii), and 45 CFR 146.111(a)(3)(iii). Back to Citation 4.  Department of Labor Technical Release 2012-01, IRS Notice 2012-17, and HHS FAQs issued February 9, 2012. Back to Citation 5.  Department of Labor Technical Release 2012-02, IRS Notice 2012-59, and HHS FAQs issued August 31, 2012. Back to Citation 6.   See 26…
72. 78 FR 57686 — Guidance Regarding Deduction and Capitalization of Expenditures Related to Tangible Property
    IRCFinal Rules (FR)Sep 19, 2013
    to taxable years beginning on or after January 1, 2012. The IRS and the Treasury Department received numerous written comments in response to the 2011 temporary and proposed regulations and held a public hearing on May 9, 2012. After considering these comments and the statements at the public hearing, the IRS and the T…
73. T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a …
    IRCTreasury DecisionsMay 7, 2007related by meaning
    INCOME TAX Rev. Rul. 2007-29 Rev. Rul. 2007-29 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2007. Announcement 2007-44 Announcement 2007-44 This anno…