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Go to T.C. Summary Op. 2003-41 (not yet in the library — opens the official source)
70 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    9 th Cir. 2012) . 329 To summarize, Thompson , the only case the opinion of the Court cites in support of its “significant comments” holdings, in fact contradicts the opinion’s conclusion. And the opinion’s repeated assertion that “Treasury was aware” of the points made by comments, see op. Ct. p. 2 69 , has no legal s…
  2. Rev. Proc. 2006-27 — Administrative programs; correction programs. This procedure updates and expands upon the Service’s comprehensive Employee Plans Compliance Resolution System (…
    IRCRevenue ProceduresSuperseded May 30, 2006
    3% of the employee’s plan compensation for each payroll period from April 1, 2003 through December 31, 2003 (resulting in elective deferrals of $960). The employee’s plan compensation for 2003 was $40,000 ($8,000 for the first three months and $32,000 for the last nine months). Employer E made matching contributions eq…
  3. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …Inc., concedes that it is not entitled to deduct repairs and maintenance expenses of $2,954 for the 2003 tax year. This petitioner concedes that it is not entitled to deduct rental expenses of $2,800 and $7,100 for the 2003 and 2005 tax years, respectively. Respondent concedes that this petitioner is entitled to deduct…
  4. T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen…
    IRCTreasury DecisionsFeb 26, 2007related by meaning
    addition, the notice invites comments from the public regarding all aspects of these provisions. ADMINISTRATIVE Rev. Proc. 2007-21 Rev. Proc. 2007-21 This procedure provides guidance to persons against whom a penalty under section 6707 or 6707A of the Code is assessed, and who may request rescission of those penalties…
  5. 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, 2006related by meaning
    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…
  6. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026related by meaning
    ic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Employer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduciary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Foreign International Sales Company. FPH—Foreign Personal Holding Company. F…
  7. U.S. Tax Court — Cynthia M. Martinez v. Commissioner
    IRCCourt RulingsDec 29, 2008
    mmissioner's denials . Washington v . Commissioner , supra at 147-152 . A . Rev . Proc . 2003-61, Sec . 4 .01--Threshold Criteria for Granting Relie f The review process begins with seven threshold criteria that a taxpayer must satisfy before the Commissioner will consider equitable relief . Rev . Proc . 2003-61, sec .…
  8. T.C. Summary Opinion 2005-127 — Timothy J. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005★ strong match
    ibed guidelines in Rev. Proc. 2003-61, 2003-2 C.B. 296, 8 to - 18 - 8 (...continued) 1 C.B. 447, and is effective either for requests for relief filed on or after Nov. 1, 2003, or for requests for which no preliminary determination letter was issued as of Nov. 1, 2003. In the present case, the request for relief was st…
  9. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    … employees' length of employment also became a problem for employees who were buying houses. During 2003 Weekend Warrior made the following payments by check to Leading Edge for management and design services: Date Amount Aug. 15, 2003 $100,000 August 2003 200,000 Aug. 21, 2003 100,000 Aug. 31, 2003 400,000 Oct. 3, 200…
  10. T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (…
    IRCTreasury DecisionsMar 7, 2005related by meaning
    Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified. EXEMPT ORGANIZATIONS T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
  11. T.C. Memo. 2010-20 — Gregory A. & Carolyn S. Prough v. Commissioner
    IRCCourt RulingsFeb 3, 2010
    …es of 3 .68 percent and 3 .06 percent, reflecting 120 percent of the Federal midterm rates for June 2003 and July 2003 . See Rev . Rul . 2003-60, 2003-1 C .B . 987, 988 ; Rev . Rul . 2003-71, 2003-2 C .B . 1, 2 . Respondent determined the maximum monthly distribution amount from the Jefferso n National annuity under th…
  12. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
  13. T.C. Summary Opinion 2007-168 — Cheryl Kunsman v. Commissioner
    IRCCourt RulingsSep 24, 2007
    on the joint return . Therefore, Rev . Proc . 2003-61, sec . 4 .02, does not apply . Rev . Proc . 2003-61, sec . 4 .03, 2003-2 C .B . at 298, provides a nonexclusive list of factors respondent considers in evaluating whether it would be inequitable to hold petitioner liable for all or part of an unpaid income tax liabi…
  14. 89 FR 20569 — Charitable Remainder Annuity Trust Listed Transaction
    IRCProposed Rules (FR)Proposed Mar 25, 2024
    … the trust instrument generally resembles one of the eight sample CRAT forms provided in Rev. Proc. 2003-53, 2003-2 C.B. 230; Rev. Proc. 2003-54, 2003-2 C.B. 236; Rev. Proc, 2003-55, 2003-2 C.B. 242; Rev. Proc. 2003-56, 2003-2 C.B. 249; Rev. Proc. 2003-57, 2003-2 C.B. 257; Rev. Proc. 2003-58, 2003-2 C.B. 262; Rev. Proc…
  15. IRCCourt RulingsOct 12, 1978related by meaning
    …a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comment letter, there are a few allegations which are prop…
  16. T.C. Summary Opinion 2005-126 — Carolyn A. Glenn v. Commissioner
    IRCCourt RulingsAug 16, 2005
    …liability. As directed by section 6015(f), the Commissioner has prescribed guidelines in Rev. Proc. 2003-61, 2003-2 C.B. 296, 9 to be considered in determining whether an individual qualifies for relief under section 6015(f). Rev. Proc. 2003-61, sec. 4.01, 2003-2 C.B. at 297, lists seven conditions which must be satisf…
  17. 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 …
  18. T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations …
    IRCTreasury DecisionsAug 6, 2007related by meaning
    to the electronic filing of certain statements that taxpayers are required to include on or with their federal income tax returns. T.D. 9332 T.D. 9332 Final, temporary, and proposed regulations under sections 883(a) and (c) of the Code relate to the exclusion from gross income of income derived by certain foreign corpo…
  19. T.C. Memo. 2019-17 — Burbach Aquatics, Inc. v. Commissioner
    IRCCourt RulingsMar 7, 2019
    $1,175 163 98 59 59 29 Concedes Equipment--Krom. 4/15/2003 7,000 7,000 -- -- -- A Equipment--Henn. 6/18/2003 15,825 15,825 -- -- -- A 4630 Equipment-- Cherokee 7/15/2003 15,000 15,000 -- -- -- -- -- B Equipment--Henn. 7/23/2003 3,200 3,200 -- -- -- B TC Equipment-- Henn. 8/1/2003 13,750 13,750 -- -- -- -- -- B Equipmen…
  20. 148 T.C. No. 14 — John C. Trimmer & Susan Trimmer v. Commissioner
    IRCCourt RulingsApr 20, 2017
    to "provide[] for a self-certification procedure" and to modify Rev. Proc. 2003-16, supra, "by providing that the Internal Revenue Service may grant a waiver during an examination". But these two purposes are accomplished in different ways. Whereas section 3 of Rev. Proc. 2016-47, 2016-37 I.R.B. at 347, provides for a …