IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsJan 27, 1998related by meaning
began on the date that the
prohibited transaction occurred, May 31, 1988, and ended on the
-14-
8
Petitioner contends that the second-tier tax of sec. 4975(b) is not applicable because of ERISA sec. 502(i), 29 U.S.C.
1132(i) (1988). ERISA sec. 502(i) provides the following:
In the case of a transaction prohibited by se…
IRCCourt RulingsNov 21, 2007
…rwork
was received from petitioner by Norwest's office in Boulder,
Colorado, on or about October 7, 1998, and was forwarded to
Norwest's home office in Minneapolis, Minnesota . The paperwork
and the stock certificate were then sent to the transfer agent on
or about October 20, 1998, and the shares of stock were
registe…
IRCCourt RulingsMar 6, 2001★ strong match
v. Commissioner
, T.C. Memo. 1998-140; Reiher v.
Commissioner
, T.C. Memo. 1998-75; Easter v. Commissioner
, T.C.
Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd.
without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette
v. Commissioner
, T.C. Memo. 1997-301; Hayes v. Commissioner
, T.C.
Memo. 1…
IRCCourt RulingsFeb 9, 2023★ strong match
…nation of the 1982 trademark licensing agreement and the 1983 licensing agreement; execution of the 1998 trademark
licenses; stipulations related to Brazilian law
On August 18, 1998, 3M Company and 3M Brazil entered into an
agreemen t terminating the 1982 trademark licensing agreement,
effective January 1, 1998.
On Aug…
IRCCourt RulingsDec 28, 2004
… of time to file. Petitioner also did not
file timely income tax returns for years before and after 1998. Petitioner filed his 1994 return on August 8, 1996, his 1995
return on February 13, 1998, his 1996 return on November 23,
1998, his 1997 return on February 4, 2001, and his 1999 return on
June 6, 2002.
On January 1…
IRCCourt RulingsNov 10, 2004★ strong match
…ent’s litigating
position that the distribution occurred in 2000. See Garcia v.
Commissioner
, T.C. Memo. 1998-203 (reaching this conclusion
regarding another question and answer contained in the same
proposed regulation), affd. without published opinion 190 F.3d
538 (5th Cir. 1999). Additionally, the substantially lev…
IRCCourt RulingsOct 24, 2007
…eview
because she trusted that Mr. Barrera “would do the best” for her
and her family.
- 13 -
7
The 1998 collection notice was not in respondent’s
administrative record and was not presented as evidence at trial.
Respondent introduced Form 4340, Certificate of Assessments,
Payments, and Other Specified Matters, dated M…
IRCCourt RulingsJun 18, 1997related by meaning
…t of statutes, must have been received for a
different purpose. See Flaherty v. Commissioner
, T.C. Memo.
- 10 -
1987-61 (holding that an Internal Revenue Service employee's
disability retirement annuity payments received under the Civil
IRCCourt RulingsOct 3, 1995related by meaning
… more equitable result. See Hildebrand v. Commissioner
, 683 F.2d 57, 58 (3d Cir. 1982), affg. T.C. Memo.
1980-532; Zadan v. Commissioner
, T.C. Memo. 1993-85. After all,
the power to legislate is exclusively the power of Congress and
not of this Court or any other. See Iselin v. United States
, 270
U.S. 245, 250 (1926…
IRCCourt RulingsAug 22, 2002
am at the University of
Phoenix commenced on September 30, 1998. The “Student Schedule
Listing” provided by petitioner shows only two courses in 1998, “Role of the Nurse Practitioner,” a three-credit course held at 6
p.m. each Wednesday between September 30, 1998 and November 4,
1998, and “Advanced Nursing Theory,” als…
IRCCourt RulingsDec 16, 1998related by meaning
xcise tax returns could have concluded that the relevant
transfer was not a prohibited transaction, or, if it was, that
it had been corrected earlier. We have carefully considered all remaining arguments made
by the parties for holdings contrary to those expressed herein,
and, to the extent not discussed above, find th…
IRCCourt RulingsJun 3, 1998★ strong match
…stituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a ruling
given to a specific taxpayer based upon the taxpayer's
specific facts and is not a ruling of general application.
See Golden Belt Tel. Association, Inc. v. Commissioner
, 108
T.C. 498, 506 (…
Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par… IRCRevenue ProceduresModified Aug 2, 2021
…Period)
+12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) Earnings for 1998 would have been increased by the amount of the Earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998 and would have been allocated as 1998 Earnings in pr…
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…Period)
+12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) Earnings for 1998 would have been increased by the amount of the Earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998 and would have been allocated as 1998 Earnings in pr…
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016
…Period) +12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) Earnings for 1998 would have been increased by the amount of the Earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998 and would have been allocated as 1998 Earnings in pr…
Rev. Proc. 2008-50 — This procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sectio… IRCRevenue ProceduresSep 2, 2008
…Period) +12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) earnings for 1998 would have been increased by the amount of the earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998 and would have been allocated as 1998 earnings in pr…
Rev. Proc. 2006-27 — Administrative programs; correction programs. This procedure updates and expands upon the Service’s comprehensive Employee Plans Compliance Resolution System (… IRCRevenue ProceduresSuperseded May 30, 2006
…Period) +12% If the $5,000 corrective contribution had been contributed for Employee X on March 31, 1998, (1) earnings for 1998 would have been increased by the amount of the earnings on the additional $5,000 contribution from March 31, 1998 through December 31, 1998, and would have been allocated as 1998 earnings in p…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
IRCCourt RulingsJul 15, 1997related by meaning
983), revg. and remanding on
another issue T.C. Memo. 1980-282; Paula Constr. Co. v.
Commissioner
, 58 T.C. 1055, 1058 (1972), affd. without published opinion 474 F.2d 1345 (5th Cir. 1973); Electric & Neon, Inc. v.
Commissioner
, 56 T.C. 1324, 1340 (1971), affd. without published
opinion 496 F.2d 876 (5th Cir. 1974); s…