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Go to T.C. Memo. 2005-114 (not yet in the library — opens the official source)
74 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014
    ctions, Credits, etc. In petitioner's 2005 Form 1120S, petitioner showed, inter alia, that during 2005 the ESOP owned 100% of the stock of petitioner. On a date not established by the record during 2006, the ESOP in question filed Form 5500, Annual Return/Report of Employee Benefit Plan (employee benefit plan 2005 annu…
  2. 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
    …ibutions. (2004 C. L.). 411(d)(6): Central Laborers’ Pension Fund v. Heinz, 124 S.Ct. 2230 (2004). (2005 C. L.). Rev. Proc. 2005-23, 2005-1 C.B. 991, as modified by Rev. Proc. 2005-76, 2005-2 C.B. 1139. (2005 C. L.). Amendments to § 1.411(d)-3 of the Final Regulations were published on August 9, 2006 (71 Fed. Reg. 4537…
  3. Notice 2005-95 — Plan amendments; retroactive annuity starting date; elective deferrals. This notice clarifies the interaction of the amendment timing deadlines for plans quali…
    IRCNoticesDec 19, 2005
    of Published Guidance Deadline to Adopt Plan Amendment under Rev. Proc. 2005-66 (or Notice 2005-5) Deadline to Adopt Plan Amendment under this Notice Retroactive Annuity Starting Date July 17, 2003 Plan years beginning on or after January 1, 2004. If discretionary — end of the plan year in which plan amendment is put …
  4. Notice 2005-101 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2005-66 pertaining to the statutory, regul…
    IRCNoticesDec 27, 2005
    , not just those on the 2005 Cumulative List. The only two items on the 2005 Cumulative List that are not yet published are listed under section 402A. The Service will not review plan language for any qualification change that becomes effective, any guidance published, or any statutes enacted after December 13, 2005, u…
  5. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011★ strong match
    in the record, petitioner was placed on disability, and she retired from the VA on February 10, 2005. I Petitioner was 46 years old when she retired. In 2005 petitioner received disabllity payments from the U.S. Office of Personnel Management (O?M) as follows: Date Gross payment Amount withheldi Net payment Oct. 14, 2…
  6. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    or documents to which § 6104 (document open to public inspection) applies, as described in section 10.03. Taxpayer may protest deletions not made .05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
  7. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    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,
  8. 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
    …d shares to pay off an exempt loan as long as equal amounts are allocated to participant accounts. (2005 C. L.). Hurricane Relief: Katrina Emergency Tax Relief Act of 2005, Pub. L. 109-73. (2005 C. L.). Notice 2005-92, 2005-2 C.B. 1165. (2005 C. L.). Announcement 2005-70, 2005-2 C.B. 682. (2005 C. L.). Gulf Opportunity…
  9. Notice 2005-84 — Minimum funding standards; disaster relief. As a result of the enactment of section 403(b) of the Katrina Emergency Tax Relief Act of 2005, the Internal Revenu…
    IRCNoticesNov 14, 2005
    2005-60, 2005-39 I.R.B. 606, which was issued on September 2, 2005, the date for performing certain acts was extended to October 31, 2005. III. RELIEF As a result of the enactment of KETRA on September 23, 2005, the October 31, 2005, date described in Notice 2005-60 for compliance with specified Code requirements was e…
  10. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
  11. Rev. Proc. 2005-66 — Qualification; determination letters; staggered remedial amendment periods. This procedure contains the Service’s procedures for issuing determination letters …
    IRCRevenue ProceduresSuperseded Sep 12, 2005
    …o be used for their first submission under the six-year remedial amendment cycle. .14 In Rev. Proc. 2005-16, 2005-10 I.R.B. 674, the Service announced the opening of the initial six-year remedial amendment cycle for defined contribution pre-approved plans. As of February 17, 2005, the Service began to accept applicatio…
  12. 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★ strong match
    …on plan. (2007 C. L.). 411(d)(6): Central Laborers’ Pension Fund v. Heinz, 124 S. Ct. 2230 (2004). (2005 C. L.). Rev. Proc. 2005-23, 2005-1 C.B. 991, as modified by Rev. Proc. 2005-76, 2005-2 C.B. 1139. (2005 C. L.). Amendments to § 1.411(d)-3 of the Final Regulations were published on August 9, 2006 (71 Fed. Reg. 4537…
  13. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
  14. Rev. Proc. 2007-44 — Qualification; determination letters; staggered remedial amendment periods. Rev. Proc. 2005-66, containing the Service’s procedures for issuing determination l…
    IRCRevenue ProceduresModified Jul 9, 2007
    … designed plans that take into account the requirements of EGTRRA and other items identified on the 2005 Cumulative List. .14 Notice 2005-95, 2005-2 C.B. 1172, discussed the general timing rules for plan amendments and provides that the deadlines set forth under section 5.05 of Rev. Proc. 2005-66 apply, with certain ex…
  15. T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409…
    IRCTreasury DecisionsJan 18, 2005★ strong match
    INCOME TAX Rev. Rul. 2005-3 Rev. Rul. 2005-3 Section 901(j)(5) Presidential waiver; Libya. Pursuant to a section 901(j)(5) Presidential waiver, section 901(j)(1) of the Code ceased to apply to Libya effective December 10, 2004. Section 911(d)(8) is not applicable to Libya after September 20, 2004, and Iraq after July 2…
  16. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    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 .…
  17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  18. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017related by meaning
    …me additional information about the tax shelter scheme to IRS and DOJ officials during the February 2005 meeting. We conclude that none of petitioner's letters or other submissions sent after that time conveyed relevant information that he had not previously provided. The only new information that petitioner submitted …
  19. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
  20. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …