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Go to T.C. Memo. 2006-220 (not yet in the library — opens the official source)
82 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    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 …
  2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  3. Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi…
    IRCRevenue RulingsJul 17, 2006★ strong match
    INCOME TAX Notice 2006-60 Notice 2006-60 This notice announces that the Treasury Department and IRS will amend regulations section 1.45D-1 to provide guidance on how an entity meets the requirements to be a qualified active low-income community business when its activities involve certain targeted populations under sec…
  4. Notice 2006-89 — Section 906 of Pension Protection Act of 2006; transition rule. This notice provides transition relief for plans of Indian tribal governments to comply with th…
    IRCNoticesModified Oct 23, 2006
    …ms of Plan B). Accordingly, Plan B is treated as a continuation of Plan A from and after October 1, 2006. (iii) Alternative reasonable and good faith compliance. As an alternative to the action under (ii) of this Example, the ITG takes action on July 1, 2007, effective as of October 1, 2006, to spin off all (or a porti…
  5. T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers …
    IRCTreasury DecisionsSep 29, 2003★ strong match
    of paragraph (c)(1)(i)(A) of this section is $15,000 for 2006 and the additional dollar amount permitted under the age 50 catch-up is $5,000 for 2006. (ii) Conclusion. C is eligible for the age 50 catch-up in 2006 because C is 55 in 2006. However, C is not eligible for the special section 457 catch-up under paragraph (…
  6. 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
    3% of the employee’s plan compensation for each payroll period from April 1, 2006 through December 31, 2006 (resulting in elective deferrals of $960). The employee’s plan compensation for 2006 was $40,000 ($8,000 for the first three months and $32,000 for the last nine months). Employer E made matching contributions eq…
  7. 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
    3% of the employee’s plan compensation for each payroll period from April 1, 2006 through December 31, 2006 (resulting in elective deferrals of $960). The employee’s plan compensation for 2006 was $40,000 ($8,000 for the first three months and $32,000 for the last nine months). Employer E made matching contributions eq…
  8. 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
    3% of the employee’s plan compensation for each payroll period from April 1, 2006 through December 31, 2006 (resulting in elective deferrals of $960). The employee’s plan compensation for 2006 was $40,000 ($8,000 for the first three months and $32,000 for the last nine months). Employer E made matching contributions eq…
  9. 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, 2006★ strong match
    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…
  10. 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,
  11. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    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…
  12. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    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 (…
  13. Notice 2006-75 — Weighted average interest rate modifications; corporate bond weighted average. This notice extends the use of the corporate bond weighted average interest rate…
    IRCNoticesSep 5, 2006
    se of the corporate bond weighted average for plan years beginning in 2006 and 2007. Corresponding changes were made to the parallel ERISA provisions. This notice provides the composite corporate bond rates from December, 2005 through July, 2006, and the resulting corporate bond weighted averages for plan years beginni…
  14. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    …re to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979-04S. Filed November 30, 2006. William Edward and Patricia Marie …
  15. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010
    …lly . Rev . Rul . 2005-66, 2005-2 C .B . 686 . Mid- and long-term rates were higher . Id . In March 2006, when Mogelefsky withdrew from Benistar Plan, the applicable Federal rate .was 4 .58 percent for a short-term loan compounded annually . Rev . Rul . 2006-10, 2006-1 C .B . 557 . The mid-term rate was 4 .51 percent, …
  16. PLR 200648028 — Definitions and Special Rules
    IRCPrivate Letter RulingsDec 1, 2006related by meaning
    INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM Third Party Communication: None Date of Communication: Not Applicable Number: 200648028 Release Date: 12/1/2006 Index (UIL) No.: 6166.00-00, 6403.00-00, 2055.00-00, 2511.02-00, 414 .00-00, 2053.09-00, 2032.00-00 CASE - MIS No.: TAM - 142156-05 AUGUST …
  17. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    …ndent 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 has jurisdiction to review an…
  18. Notice 2008-73 — This notice expands the availability of the transition relief for certain small pension plans that was originally provided in Notice 2008-21, 2008-7 I.R.B. 431…
    IRCNoticesSep 22, 2008
    uation date for the second plan year that begins before 2008 (the 2006 plan year), including the increase in current liability for the 2006 plan year. For purposes of determining the FTAP for the 2007 plan year, the value of net plan assets is determined as the value of plan assets under § 412(c)(2) as in effect for th…
  19. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    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))…
  20. 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 .…