Notice 2014-19 — The purpose of this notice is to provide guidance on the application (including the retroactive application) of the decision in United States v. Windsor, 570 U… IRCNoticesApr 21, 2014
…uired to be operated in a manner that reflects the outcome of Windsor and the guidance in Rev. Rul. 2013–17? A–2. Qualified retirement plan operations must reflect the outcome of Windsor as of June 26, 2013. A retirement plan will not be treated as failing to meet the requirements of section 401(a) merely because it di…
IRCCourt RulingsApr 2, 2024related by meaning
is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8
(2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on
the date which is 60 days after the later of . . . [the] earliest incident date . . …
Notice 2013-23 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesApr 15, 2013★ strong match
…e to the delayed publication of some IRS forms relating to the 2012 tax year.
EMPLOYEE PLANS
Notice 2013-23 Notice 2013-23 Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond weighted average interest rate for pla…
Rev. Proc. 2015-27 — This revenue procedure contains modifications to Revenue Procedure 2013–12, 2013–4 I.R.B. 313. The modifications reflected in this revenue procedure include mi… IRCRevenue ProceduresApr 20, 2015
…nt benefits on a tax-favored basis. The most recent restatement of EPCRS is set forth in Rev. Proc. 2013–12, 2013–4 I.R.B. 313. The modifications to Rev. Proc. 2013–12 reflected in this revenue procedure include miscellaneous changes made to improve EPCRS, such as reducing VCP compliance fees relating to failures to me…
IRCCourt RulingsSep 25, 2019★ strong match
… T.C. 518, 520
- 11 -
[*11] (1992), affd, 17 F.3d 965 (7th Cir. 1994); Murphy v. Commissioner, T.C.
Memo. 2019-72, at *7.
The regulations provide that a taxpayer has reasonable cause for failure to
timely pay a tax if "the taxpayer has made a satisfactory showing that he exercised
ordinary business care and prudence in…
78 FR 78520 — Appraisals for Higher-Priced Mortgage Loans IRCFinal Rules (FR)Dec 26, 2013
2013. The Final Rule was published in the
Federal Register
on February 13, 2013, and is effective on January 18, 2014.
See78 FR 10368 (Feb. 13, 2013). The preamble to the January 2013 Final Rule stated that the Agencies would consider exemptions for three additional types of transactions that commenters requested the A…
Notice 2013-58 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in September 2013; the 24-month average segment rat… IRCNoticesSep 30, 2013
…ding target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from August 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of August 2013 are, respectively, 1.36, 4.60, and 5.58. For plan years beginning on or after January 1, 201…
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,
Ann. 2013-15 — This announcement contains a revised Exhibit: Sample Notice to Interested Parties, attached to Rev. Proc. 2013-6, 2013-1 I.R.B. 198. The Exhibit is revised to … IRCAnnouncementsMar 11, 2013
Announcement 2013-15
This announcement contains a revised Exhibit: Sample Notice to Interested Parties, attached to Rev. Proc. 2013-6, 2013-1 I.R.B. 198. The Exhibit is revised to include the correct addresses for submitting applications for determination letters and comments submitted by interested parties, in accorda…
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…
Notice 2013-66 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in October 2013; the 24-month average segment rates… IRCNoticesNov 12, 2013
…g target. Pursuant to Notice 2007–81, the monthly corporate bond yield curve derived from September 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of September 2013 are, respectively, 1.40, 4.66, and 5.62. For plan years beginning on or after January 1, …
Notice 2013-75 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond … IRCNoticesDec 2, 2013
…ing target. Pursuant to Notice 2007-81, the monthly corporate bond yield curve derived from October 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of October 2013 are, respectively, 1.24, 4.47, and 5.52. For plan years beginning on or after January 1, 20…
Notice 2013-85 — This notice contains updates for the corporate bond weighted average interest rate for plan years beginning in December 2013; the 24-month average segment rate… IRCNoticesDec 23, 2013
…ng target. Pursuant to Notice 2007–81, the monthly corporate bond yield curve derived from November 2013 data is in Table I at the end of this notice. The spot first, second, and third segment rates for the month of November 2013 are, respectively, 1.19, 4.53, and 5.66. For plan years beginning on or after January 1, 2…
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 2014-48 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for July 2014 used under § 417(e)(3)(D), the 24-… IRCNoticesSep 2, 2014
…ctions, and transition issues.
EFFECT ON OTHER DOCUMENTS
The following Notices are modified:
Notice 2013–11, 2013–11 I.R.B. 610,
Notice 2013–23, 2013–16 I.R.B. 906,
Notice 2013–28, 2013–19 I.R.B. 1039,
Notice 2013–32, 2013–22 I.R.B. 1137,
Notice 2013–37, 2013–26 I.R.B. 1269,
Notice 2013–46, 2013–31 I.R.B. 117,
Notice 2…
IRCCourt RulingsJun 6, 2019related by meaning
ng a deficiency after issuing a
refund. McCree v. Commissioner, at *18-*20.
It is clear from our review of the record that SO Taylor verified that the requirements of any applicable law and administrative procedure were followed
- 20 -
[*20] and that in sustaining the proposed levy against petitioner, SO Taylor
properl…
Ann. 2013-13 — This announcement contains corrections to Revenue Procedure 2013-6, 2013-1 I.R.B. 198, as published on January 2, 2013. In particular, this announcement clarif… IRCAnnouncementsFeb 25, 2013
Announcement 2013-13
This announcement contains corrections to Revenue Procedure 2013-6, as published on January 2, 2013 (2013-1 I.R.B. 198). In particular, this announcement clarifies that applications for determination letters should continue to be submitted to the Covington, KY address in section 6.15 of Rev. Proc. …
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 .…
IRCCourt RulingsMar 14, 2019related by meaning
appears on dozens of other documents in the record. In any event petitioner offered no plausible explanation about
where the money went if not to him. 4We do not believe that respondent was obligated to concede the inapplicability of the section 72(t) additional tax or the nontaxability of $737 in miscellaneous income.…
IRCCourt RulingsMar 31, 2015related by meaning
T.C. Memo. 2013-261 (remanding when it was unclear whether
- 39 -
[*39] the settlement officer properly considered the taxpayer's health in rejecting the taxpayer's OIC with special circumstances); Leago v. Commissioner, T.C.
Memo. 2012-39 (same); see also Antioco v. Commissioner, T.C. Memo. 2013-35
(remanding when th…