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Go to T.C. Memo. 2013-67 (not yet in the library — opens the official source)
76 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 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…
  2. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    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…
  3. 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…
  4. 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…
  5. 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…
  6. 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 …
  7. 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…
  8. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    …le cause and good faith. Higbee v. Commissioner, 116 T.C. at 449 (citing Remy v. Commissioner, T.C. Memo. 1997-72). The many section 72(t) cases, just some of which have been cited supra pp. 7-8, strongly indicate a common misunderstanding among taxpayers that financial hardship is an exception to the section 72(t) add…
  9. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019related by meaning
    DRC T.C. Memo. 2019-67 UNITED STATES TAX COURT MARIA SHENORAH MCCREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10129-14L. Filed June 6, 2019. Maria Shenorah McCree, pro se. Moenika N. Coleman, Linda L. Wong, Michael S. Navarro, and Cindy L. Wofford, for respondent. MEMORANDUM FINDINGS OF FA…
  10. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    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.…
  11. 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…
  12. 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, …
  13. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
  14. 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…
  15. 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…
  16. T.C. Memo. 2018-49 — Stacey S. Marks v. Commissioner
    IRCCourt RulingsApr 10, 2018related by meaning
    JRN T.C. Memo. 2018-49 UNITED STATES TAX COURT STACEY S. MARKS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18520-16. Filed April 10, 2018. Ray C. Mayo, Jr., for petitioner. Donielle A. Hubbard, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MORRISON, Judge: Respondent mailed petition…
  17. 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…
  18. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
  19. 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. …
  20. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…