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 …
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 EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn.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 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 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 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 RulingsJun 13, 2017★ strong match
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 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…
IRCCourt RulingsSep 24, 2007
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 RulingsOct 19, 2010related by meaning
… •
warnings that he was in danger of being penalized. For example,
in Mathews v. Commissioner, T.C. Memo. 2005-84, we told
petitioner:
"Even though the filing of the petition resulted in
respondent's concession of the sec. 72(t) additional tax,
IRCCourt RulingsFeb 10, 1997related by meaning
… filed, and thus
become a part of the record. They are accordingly referred to in
this Supplemental Memorandum Opinion to the extent we deem it
necessary to do so to address arguments contained in petitioner's
Motion and Judicial Notice Motions.
- 4 -
Rule 201(f) of the Federal Rules of Evidence provides that
judicial …
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
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…
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…
IRCCourt RulingsFeb 9, 2023related by meaning
… and June
30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon
Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M.
(CCH) 1707 (a case involving tax years 1979, 1980, and
1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d
825 (5th Cir. 1996)
In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
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…
Rev. Proc. 2006-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2006
…ed an automatic change procedure for obtaining a change in annual accounting period. See Rev. Proc. 2002-39, 2002-1 C.B. 1046 (general procedures for prior approval), as clarified and modified by Notice 2002-72, 2002-2 C.B. 843, and modified by Rev. Proc. 2003-34, 2003-1 C.B. 856, and Rev. Proc. 2003-79, 2003-2 C.B. 10…
IRCCourt RulingsNov 7, 1996related by meaning
is written, and, even if
petitioner's argument might accord with good policy, we are not
at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy
, 516
U.S.
116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing
Badaracco v. Commissioner
, 464 U.S. 386, 398 (1984))…
Rev. Proc. 2005-3 — Areas in which rulings will not be issued (domestic areas). This procedure provides a revised list of those provisions of the Code under the jurisdiction of th… IRCRevenue ProceduresJan 3, 2005
…ed an automatic change procedure for obtaining a change in annual accounting period. See Rev. Proc. 2002-39, 2002-1 C.B. 1046 (general procedures for prior approval), as clarified and modified by Notice 2002-72, 2002-2 C.B. 843, and modified by Rev. Proc. 2003-34, 2003-1 C.B. 856, and Rev. Proc. 2003-79, 2003-2 C.B. 10…