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64 documents · 0.50sAllIRCERISAPBGCJoint Board
  1. Ann. 2007-68 — This document contains numerous corrections to the preamble of final regulations (T.D. 9321, 2007-19 I.R.B. 1123) setting forth guidance on the application of …
    IRCAnnouncementsAug 6, 2007
    …easury. SUMMARY: This document contains corrections to final regulations (T.D. 9321, 2007-19 I.R.B. 1123) that were published in the Federal Register on Tuesday, April 17, 2007 (73 FR 19234), relating to section 409A. DATES: This correction is effective April 17, 2007. FOR FURTHER INFORMATION CONTACT: Stephen Tackney, …
  2. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
  3. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    foregoing statutory - 19 - requirements were satisfied for the audit year. Therefore, we reject petitioner’s claim, raised at trial, to deductions for three dependency exemptions. VI. Respondent’s Section 72(t) Determination Section 72(t) provides, in pertinent part, as follows: SEC. 72(t). 10-Percent Additional Tax on…
  4. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  5. 154 T.C. No. 6 — Sandra M. Conard v. Commissioner
    IRCCourt RulingsMar 10, 2020
    … of section 72(t) as part of what became the Tax Reform Act of 1986 (TRA), Pub. L. No. 99-514, sec. 1123(a), 100 Stat. at 2472, the Senate Finance Committee reasoned that "[t]he absence of withdrawal restrictions in the case of some tax-favored arrangements allows participants in those arrangements to treat them as gen…
  6. T.C. Memo. 1998-13 — Francisco A. Murillo v. Commissioner
    IRCCourt RulingsJan 12, 1998related by meaning
    ontrol of the use of the IRA distributions. We are not persuaded by respondent's argument that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the forfeiture, and his avoidance of a fine or potentially longer prison sentence, petitioner should be treated …
  7. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    rticle 12 of Law No. 4,131, of September 3, 1962. ANTONIO DELFIM NETTO The English portion of Exhibit 31 - J (Portaria 60/94 ) is: MF Ordinance No. 60 D.O.U.: 2/01/1994 The MINISTER OF FINANCE, in exercise of its statutory duties, taking into view the provisions of art. 50 of Law No. 8,383, of December 30, 1991 and Ord…
  8. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  9. PLR 200820009 — Investment in Contract
    IRCPrivate Letter RulingsMay 16, 2008
    … the last year beginning before January 1, 1989. P.L. 99-514 (“the Tax Reform Act of 1986”) section 1123(e)(2), as amended by P.L. 100-647 (“TAMRA”) section 1011A(c)(11).
  10. T.C. Memo. 2003-156 — Michael W. Duncan v. Commissioner
    IRCCourt RulingsMay 28, 2003
    …s seldom available. Petzoldt v. Commissioner , supra at 699; Rowlee v. Commissioner , 80 T.C. 1111, 1123 (1983). Consequently, the Commissioner may prove fraud by circumstantial evidence. Toussaint v. Commissioner , supra at 312 ; Rowlee v. Commissioner , supra at 1123; see Marsellus v. Commissioner , 544 F.2d 883, 885…
  11. 92 T.C. 866; 92 T.C. No. 51 — Welander v. Commissioner
    IRCCourt RulingsApr 19, 1989
    …Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. Pub. L. 99-614, sec. 1123(d)(2), 100 Stat. 2085, 2475. But see Code sec. 72(t) added by the same Act, sec. 1123(a).
  12. I.R.C. § 408(e) — Individual retirement accounts
    IRCCode / StatuteJan 6, 2025
    (e) (e) Tax treatment of accounts and annuities [(f) Repealed. Pub. L. 99–514, title XI, §1123(d)(2), Oct. 22, 1986, 100 Stat. 2475] (e)(1) (1) Exemption from tax Any individual retirement account is exempt from taxation under this subtitle unless such account has ceased to be an individual retirement account by reason…
  13. 35 T.C. 1238 — Kimble Glass Co. v. Commissioner
    IRCCourt RulingsMar 31, 1961
    …veral planned steps. Distributors Finance Corporation, 20 T.C. 768; Charles B. Mathis, Jr., 19 T.C. 1123. It is concluded that the 1949 transaction was not a part II transaction.
  14. Treas. Reg. § 1.403(b)-6(d) — Timing of distributions and benefits.
    IRCRegulationsSep 17, 2024
    …xable year beginning before January 1, 1989 (which does not apply to earnings thereon), see section 1123(e)(3) of the Tax Reform Act of 1986 (100 Stat. 2085, 2475) Public Law 99-514, and section 1011A(c)(11) of the Technical and Miscellaneous Revenue Act of 1988 (102 Stat. 3342, 3476) Public Law 100-647.
  15. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    is Court. Section 72(t) provides that: (1) * * * If any taxpayer receives any amount from a qualified retirement plan (as defined in section 4974(c)), the taxpayer's tax * * * shall be increased by an amount equal to 10 percent of the portion of such amount which is includible in gross income. Section 72(t)(2) provides…
  16. 78 T.C. 979; 78 T.C. No. 69 — Ruggere v. Commissioner
    IRCCourt RulingsJun 14, 1982related by meaning
    nder the Sixth and Ninth Amendments of the Constitution were not violated by our actions in the instant case. Decision will be entered under Rule 155. By stipulation, respondent concedes that the $1,562 figure is the product of an erroneous computation in the statutory notice of deficiency and that should respondent pr…
  17. Notice 2010-6 — This notice provides rules governing the taxation of nonqualified deferred compensation plans. Section 409A of the Code requires that a nonqualified deferred c…
    IRCNoticesModified Jan 19, 2010
    …§ 409A were issued by the IRS and the Treasury Department on April 17, 2007 (T.D. 9321, 2007-1 C.B. 1123 [72 Fed. Reg. 19234]), effective for taxable years beginning on or after January 1, 2009 (see Notice 2007-86, 2007-2 C.B. 990).
  18. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    ights-related activity. And since none of petitioner's compensation for the year was includable in gross income, all of petitioner's IRA contributions for the year are nondeductible. Secs. 219(b), 408(o). Contributions are deemed to have been made to an IRA on the last day of the preceding taxable year if the contribut…
  19. PLR 201111016 — Qualified Pension, Profit-Sharing, and Stock Bonus Plan
    IRCPrivate Letter RulingsMar 18, 2011
    …e last year beginning before January 1,1989. P.L. 99-514 (lithe Tax Reform Act of 5 1986"), section 1123(e)(2), as amended by P.L. 100-647 ("TAIVlRA") section 1011A(c)(11 ). Section 408(b) of the Code defines an individual retirement annuity ("IRA") as an annuity or endowment contract which is issued by an insurance co…
  20. PLR 201313027 — Taxability of Beneficiary of Employee's Trust (Time and Manner of Taxation)
    IRCPrivate Letter RulingsMar 29, 2013related by meaning
    - ID: Office: UILC: CCA_2012121308293246 -------------------------- 402.00-00, 1311.00-00 Number: 201313027 Release Date: 3/29/2013 From: --------------------- Sent: Thursday, December 13, 2012 8:29:34 AM To: -------------------- Cc: Subject: RE: CCA - -------- This email follows up on the email below. We have reviewed…