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Go to T.C. Summary Op. 2013-95 (not yet in the library — opens the official source)
76 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    was the only exception intended by Congress, since, had it intended any other, it would similarly have been specifically stated in the Code. We agree. Substantially the same argument made by petitioners was made and rejected in Sullivan v. Commissioner, 76 T.C. 1156 (1981), affd. by unpublished order (10th Cir. 1983). …
  3. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025related by meaning
    …matter of law . See Rule 121(a)(2); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant summary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party. Sundstrand Corp. , 98 T.C. at 520. The nonmoving party may not rest upon mere allegations…
  4. T.C. Memo. 2017-186 — Joe Pokawa & Nancy Fatoma v. Commissioner
    IRCCourt RulingsSep 21, 2017
    es of $53,114 from AT&T in 2013 and $5,984 from Ad Susman & Associates, Inc., in 2014. After losing his job with AT&T Mr. Pokawa withdrew money from a retirement account to invest in various business activities. The withdrawals were reported on Forms 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-…
  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. 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…
  7. 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 …
  8. 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…
  9. 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 …
  10. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    stock. But in substance there was an established expectation and intention that commission payments would be made, and the Roth IRAs were directed to purchase the FSC stock on the basis of that expectation and intention. The formal basis for the purchase price therefore did not reflect the substance of the relatedpart…
  11. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    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…
  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 2002-51 — James Joseph Timmerman v. Commissioner
    IRCCourt RulingsMay 9, 2002related by meaning
    e underpayment which is attributable to any substantial understatement of income tax. Sec. 6662(b)(2). A “substantial understatement” exists where the amount of the understatement exceeds the greater of 10 percent of the tax required to be shown on the return for the taxable year or $5,000. Sec. 6662(d)(1). No penalty …
  14. T.C. Memo. 2011-106 — Fredric J. & Dushanka Lowe v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Either party may move for summary adjudication upon all or any part of the legal issues in controversy. Rule 121(a). Full or partial summary judgment is appropriate where the record shows that there is no genuine issue as to any material fact and that a decisi…
  15. 133 T.C. No. 9 — Taproot Administrative Services, Inc. v. Commissioner
    IRCCourt RulingsSep 29, 2009related by meaning
    …eflect .the foregoing, An appropriate order will be issued granting respondent's motion for partial summary judgment . Reviewed by the Court . COLVIN,COHEN, WELLS, HALPERN, VASQUEZ, GALE, THORNTON .,, MARVEL, GOEKE, GUSTAFSON, and PARIS, JJ ., agree with this majority opinion .- 25 ( . continue d traditional and Roth I…
  16. Ann. 2013-21 — This announcement provides a revised Acknowledgment Letter, attached to Rev. Proc. 2013-12, 2013-4 I.R.B. 313. The telephone number that taxpayers use to inqui…
    IRCAnnouncementsApr 22, 2013
    Announcement 2013-21 Revised Exhibit: Acknowledgement Letter Employee Plans Voluntary Correction Program (VCP) Submissions The telephone number that taxpayers use to inquire about the status of a Voluntary Correction Program (“VCP”) submission that has been sent to the IRS has changed as of March 27, 2013. The new numb…