Notice 2007-3 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66, 2005-2 C.B. 509, pertaining to th… IRCNoticesModified Jan 8, 2007
w comparability plans were published on June 29, 2001 (66 Fed. Reg. 34535). (2005 C. L.).
Rev. Rul. 2004-21, 2004-1 C.B. 544. (2005 C. L.).
401(a)(9): Sections 1.401(a)(9)-1 through -9 of the Regulations were published on April 17, 2002 and June 15, 2004 (67 Fed. Reg. 18988 and 69 Fed. Reg. 33288). (2004 C. L.).
401(a)…
Notice 2007-94 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-28 I.R.B. 54, pertaining to … IRCNoticesDec 17, 2007
hrough -9 of the Regulations were published on April 17, 2002 and June 15, 2004 (67 Fed. Reg. 18988 and 69 Fed. Reg. 33288). (2004 C. L.).
401(a)(17): Section 401(a)(17) of the Code was amended by § 611(c) of EGTRRA to increase the compensation limit to $200,000. (2004 C. L.).
Notice 2001-56, 2001-2 C.B. 277. (2004 C. …
IRCCourt RulingsMar 6, 2001★ strong match
claim to a pension plan
contribution deduction on that ground forecloses her claim that
she is entitled to an above-the-line Schedule C deduction for legal fees, rather than the itemized deduction subject to the 2percent limitation of section 67 that respondent allowed in the
statutory notice.
To give effect to all the…
IRCCourt RulingsJun 15, 2009
…t he isentitled for his taxable certain itemized deductions in excess of those tha t
claimed in the 2004] joint return .
Claimed Errors in the 2004 Notic e
The parties stipulated :
his burde n
year1j2004 to
the Haigh s
"Petitioner and respondent
!
;, ;agre e
that the proposed adjustments in tax liability included in th…
Notice 2008-108 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the… IRCNoticesDec 15, 2008
…ulations relating to new comparability plans were published on June 29, 2001 (66 Fed. Reg. 34535). (2004 C. L.).
Rev. Rul. 2001-30, 2001-2 C.B. 46. (2004 C. L.).
Amendments to § 1.401(a)(4)-9 of the Regulations relating to new comparability plans were published on June 29, 2001 (66 Fed. Reg. 34535). (2005 C. L.).
Rev. …
IRCCourt RulingsMay 19, 2011
in
2004. Leading Edge issued Forms W-2 for 2004 and filed Forms 941
for every quarter of 2004.
Weekend Warrior continued to experience working capital shortfalls, and it borrowed money from Leading Edge and Mr.
Warmoth. Between April 1 and December 31, 2004, Weekend Warrior
signed several promissory notes. On April 1, …
Notice 2004-84 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Announcement 2004-71, 2004-40 I.R.B. 569, pertaining … IRCNoticesModified Dec 27, 2004
The 2004 Cumulative List is to be used primarily by plan sponsors and practitioners in drafting defined contribution pre-approved plans (that is, defined contribution plans that are master and prototype (M&P) or volume submitter (VS) plans) for their first submission under the proposed remedial amendment cycle. As a co…
IRCCourt RulingsSep 24, 2007related by meaning
moot, or irrelevant .
To reflect the foregoing,
Decision will be entere d
for respondent .
8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the
tax shown on the taxpayer's return for the year in question (or,
if no return is filed, the taxpayer's tax…
Notice 2009-98 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the… IRCNoticesDec 28, 2009
…to permit distributions of elective deferrals from a § 401(k) plan upon severance from employment. (2004 C. L.).
Notice 2002-4, 2002-1 C.B. 298. (2004 C. L.).
Section 636(a) of EGTRRA directed the Secretary of the Treasury to revise the regulations relating to safe harbor hardship distributions of elective deferrals fr…
IRCCourt RulingsJul 14, 2005related by meaning
number of TLC's customers applied the sec. 274(n)(1) limitation
to any amounts that they paid to TLC.
"Even if we were to allow petitioner to advance petitioner's tax duplication argument, petitioner would not be
entitled to the remedy it seeks. If, as petitioner asserts,
certain trucking company clients applied the s…
Notice 2004-59 — Alternative deficit reduction election; amendment following election. This notice provides guidance on the restrictions that are placed on plan amendments foll… IRCNoticesSep 7, 2004
…Income Security Act of 1974 (“ERISA”), as added by section 102 of the Pension Funding Equity Act of 2004, Pub. L. 108-218 (“PFEA ’04”).
I. Background Section 102 of PFEA ’04, which was enacted on April 10, 2004, added § 412(l)(12) to the Code and section 302(d)(12) to ERISA. Section 412(l)(12) of the Code permits certa…
IRCCourt RulingsMay 29, 2002related by meaning
… however, there was no levy by respondent in this case.
Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13,
affd. without published opinion 166 F.3d 1201 (2d Cir. 1998),
also cited by petitioner, the taxpayer was indicted on charges of
violating Federal currency transaction reporting laws. As part
of the taxpaye…
IRCCourt RulingsJun 25, 2012related by meaning
…me to verify, adequate substantiation for the matters in question. See Nguyen
v. Commissioner, T.C. Memo. 2003-313 (and cases cited therein). Factual determinations were required to decide whether the distributions from NADA
were taxable, whether the 10% additional tax applied, and whether petitioner was
- 10 -
entitle…
Rev. Rul. 2004-65 — Post-retirement health benefits; waiver. This ruling holds that an employer has reduced retiree health coverage, within the meaning of section 420(c)(2)(E) of … IRCRevenue RulingsJul 6, 2004
INCOME TAX
Rev. Rul. 2004-63 Rev. Rul. 2004-63
Special use value; farms; interest rates. The 2004 interest rates to be used in computing the special use value of farm real property for which an election is made under section 2032A of the Code are listed for estates of decedents.
Rev. Rul. 2004-66 Rev. Rul. 2004-66
Fede…
Notice 2006-105 — Minimum funding standards; alternative deficit reduction contribution. This notice describes how a commercial passenger airline may make an election of an alte… IRCNoticesDec 11, 2006
…es identical requirements with respect to the minimum funding standard of section 302. Announcement 2004-38, 2004-1 C.B. 878, provides procedures for electing an alternative deficit reduction contribution including a model election form. Announcement 2004-43, 2004-1 C.B. 955, provides guidance on the types of notices t…
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 .…
Ann. 2004-51 — This announcement corrects an error in section V. of Announcement 2004-43, 2004-21 I.R.B. 955, and restates the section as corrected. Announcement 2004-43 corr… IRCAnnouncementsJun 7, 2004
Announcement 2004-51
Correction to Announcement 2004-43
This is to correct an error in the second sentence of section V. of Announcement 2004-43, 2004-21 I.R.B. 955. The phrase “that begins during calendar 2004” should read “that begins before April 1, 2004.”
As a result, section V. is corrected to read as follows…
IRCCourt RulingsJun 3, 1998related by meaning
…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 (…
IRCCourt RulingsNov 18, 2009
…ation * * * .
r Petitioners filed Form 1040, U .S . Individual Income Ta x
Return, for taxable year 2004 (2004 return) . In that return,
petitioners included in gross income the 2004 IRA distribution of
$397,994 .60 that Mr . Willhite received during 2004 . Petitioners
did not 'report in the 2004 return that they are s…
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 …