IRCPrivate Letter RulingsJun 11, 2004★ strong match
…'s consent to effect the change and to
prevent amounts from being duplicated or omitted.
Rev. Proc. 2002-9, 2002-1 C.B. 32, provides the exclusive procedures by which
a taxpayer may obtain the automatic consent of the Commissioner to make the changes
in method of accounting described in that revenue procedure’s APPENDI…
IRCCourt RulingsMay 19, 2011
… employees in 2000-2003.
Leading Edge did not provide health insurance benefits to its
employees in 2002-04. Leading Edge maintained a portfolio account with Advest,
Inc. From August 2003 through December 2004 Leading Edge
- 20 -
maintained a portfolio of stocks and received dividends."
Leading Edge also maintained che…
REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R… IRCProposed Rules (FR)Proposed Sep 24, 2007
…2006-36 I.R.B. 353; Rev. Rul. 2005-24, 2005-1 C.B. 892; Rev. Rul. 2003-102, 2003-2 C.B. 559; Notice 2002-45, 2002-2 C.B. 93; Rev. Rul. 2002-41, 2002-2 C.B. 75; Rev. Rul. 69-141, 1969-1 C.B. 48. New section 106(e) provides that a health FSA will not fail to satisfy the requirements of sections 105 or 106 merely because …
IRCCourt RulingsSep 24, 2007★ strong match
him . On May 24, 2002,
SBC Communications, Inc ., issued a check to petitioner in the
amount of $131,317 .46 . The gross amount of the check had been $168,355 .71 . However, $33,671 .14 in Federal income tax and
$3,367 .11 in California State income tax had been withheld .
During 2002, petitioner also received $9,552 …
IRCCourt RulingsJan 27, 2014
… 20%. Mr. Ries, a disqualified person, is therefore
treated as owning all of petitioner's stock for 2002. See secs. 409(p)(3),
-14- [*14] 318(a)(1)(A); sec. 1.409(p)-1(e)(2), Income Tax Regs. Accordingly, 2002 is
a nonallocation year. See sec. 409(p)(3).
D. The Plan Violated Section 409(p) for 2002.
The Plan made an im…
IRCCourt RulingsJul 13, 2010
…member . Ms . O'Boyle received nonemployee compensation from Red Barn
Actors studio during 2001 and 2002 .
Neither petitioner was employed by any third party during
2000, 2001, or 2002 .
Petitioners did not file a timely .tax return for the 2000,
2001, or 2002 tax years .
Mr . O'Boyle paid $10,000 toward his potential …
IRCCourt RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…
IRCCourt RulingsJan 31, 2008
…. Commissioner , 93 T .C . 181,
195 (1989) . The record establishes, and we have found, that
during 2002 Mr . Bangs paid to Ms . Platt $8,803 .87 pursuant to the
divorce decree provision in question .
Date of Payment Amount . of Paymen t
01/14/2002 728 .9 1
02/13/2002 728 .9 1
03/13/2002 728 .9 1
04/15/2002 728 .9 1
05…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
INCOME TAX
Rev. Rul. 2006-41 Rev. Rul. 2006-41
LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
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 .…
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
addition, the notice invites comments from the public regarding all aspects of these provisions.
ADMINISTRATIVE
Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…
IRCCourt RulingsMar 6, 2001★ strong match
…75), affd. without published opinion 552 F.2d 368
(5th Cir, 1977); Kiourtsis v. Commissioner
, T.C. Memo. 1996-534; Fitzpatrick v. Commissioner
, T.C. Memo. 1995-548. Even after she
received the no change letter, petitioner was aware that the 1992
tax year remained open. Petitioner signed three consents to
extend the t…
T.D. 9641 — These final regulations contain amendments relating to certain cash or deferred arrangements under section 401(k) and matching contributions and employee contr… IRCTreasury DecisionsDec 9, 2013related by meaning
INCOME TAX
Rev. Rul. 2013–26 Rev. Rul. 2013–26
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 December 2013.
EMPLOYEE PLANS
T.D. 9641 T.D. 9641
These final…
Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k… IRCNoticesJun 8, 2026related by meaning
B. 2026-01 143
2026-4 2026-01 I.R.B. 2026-01 160
2026-5 2026-01 I.R.B. 2026-01 258
2026-6 2026-02 I.R.B. 2026-02 314
2026-7 2026-02 I.R.B. 2026-02 316 2026-8 2026-04 I.R.B. 2026-04 380
2026-9 2026-04 I.R.B. 2026-04 393
2026-10 2026-04 I.R.B. 2026-04 394
2026-12 2026-07 I.R.B. 2026-07 535
2026-13 2026-09 I.R.B. 2026-09 …
IRCRegulationsDec 30, 2016
…e for the year. Thus, the second condition in paragraph (c) of this Q&A-8 is also satisfied for the 2002 plan year. Because both conditions in paragraph (c) of this Q&A-8 are satisfied for 2002, with respect to any qualifying event occurring in 2002, the health FSA is not obligated to make COBRA continuation coverage a…
IRCPrivate Letter RulingsMar 3, 2000related by meaning
…C:EBEO:4
TL-N-4712-99
UILC: 419.00-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR
FROM: Assistant Chief Counsel (Employee Benefits and Exempt
Organizations) CC: EBEO
SUBJECT:
This Field Service Advice is in res ponse to your memorandum dated October 5,
1999. Field Service Advice is not …
IRCCourt RulingsJun 13, 2017
that petitioner had provided to CID in the 2002 letters. Petitioner
attached copies of the 2002 letters to the 2002 Form 211. On February 3, 2003, he received a letter from the IRS Midstates Region office in Memphis, Tennessee,
verifying that the 2002 Form 211 had been received and was being evaluated.
2004
In October…
IRCCourt RulingsJan 3, 2017related by meaning
v.
Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo.
2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v.
- 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001).
While we acknowledge and are sympathetic to petitioner's financial straits, we
have no aut…
Notice 2004-34 — Minimum funding standards; interest rates; section 101 of Pension Funding Equity Act. This notice describes the method for determining the permissible range of… IRCNoticesMay 3, 2004
….39
6.65
7.39
2001
October
7.37
6.64
7.37
2001
November
7.36
6.62
7.36
2001
December
7.34
6.61
7.34
2002
January
7.34
6.60
7.34
2002
February
7.33
6.60
7.33
2002
March
7.32
6.59
7.32
2002
April
7.32
6.58
7.32
2002
May
7.31
6.58
7.31
2002
June
7.30
6.57
7.30
2002
July
7.28
6.55
7.28
2002
August
7.26
6.53
7.26
2002
Septe…
IRCPrivate Letter RulingsMar 10, 2006related by meaning
… 86,112 sets forth a defined set of
circumstances in which the Service may apply a technical advice memorandum (TAM)
that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer.
Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under
§ 7805(b) an Associate Chief Counsel, as…