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Go to T.C. Summary Op. 2017-72 (not yet in the library — opens the official source)
68 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. Treas. Reg. § 1.430(j)-1(f) — Payment of minimum required contributions.
    IRCRegulationsSep 9, 2016
    r the 3 1/2-month period between April 15, 2017 and January 1, 2017 valuation date using the plan's effective interest rate, for a result of $86,620 (that is, $90,000 ÷ 1.1090(2.5/12) ÷ 1.0590(3.5/12)).(v) The remainder of the required installment that was due on April 15, 2017 without regard to the liquidity requireme…
  2. T.D. 9732 — These final regulations provide guidance on the determination of minimum required contributions for single-employer defined benefit pension plans and also cont…
    IRCTreasury DecisionsSep 28, 2015
    January 1, 2017 valuation date using the plan’s effective interest rate, for a result of $86,620 (that is, $90,000 ÷ 1.1090(2.5/12) ÷ 1.0590(3.5/12)). (v) The remainder of the required installment that was due on April 15, 2017 without regard to the liquidity requirement ($20,000) remains unpaid until the July 15, 2017…
  3. 80 FR 54374 — Determination of Minimum Required Pension Contributions
    IRCFinal Rules (FR)Sep 9, 2015
    d the April 15, 2017 due date using the plan's effective interest rate increased by 5 percentage points (10.90%), and further discounted for the 3 1/2 -month period between April 15, 2017 and January 1, 2017 valuation date using the plan's effective interest rate, for a result of $86,620 (that is, $90,000 ÷ 1.1090(2.5/…
  4. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    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 . . …
  5. Notice 2017-37 — This notice contains the Cumulative List of Changes in Plan Qualification Requirements for Pre-Approved Defined Contribution Plans for 2017 (2017 Cumulative Li…
    IRCNoticesJul 17, 2017
    …List, see https://www.irs.gov/retirement-plans/operational-compliance-list. III. APPLICATION OF THE 2017 CUMULATIVE LIST This notice relates to the opinion letter program for pre-approved defined contribution plans. The third six-year remedial amendment cycle for pre-approved defined contribution plans began February 1…
  6. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    , education, and sophistication of the taxpayer; however, the principal consideration is the extent of the taxpayer's efforts to assess the proper tax liability. R; see also Higbee v. Commissioner, 116 T.C. at 448. Taking into consideration the taxpayer's experience, education, and sophistication, an honest misundersta…
  7. Notice 2017-76 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for December 2017 used under § 417(e)(3)(D), the…
    IRCNoticesDec 26, 2017
    39 I.R.B. 408, Notice 2016–54, 2016–40 I.R.B. 429, and Notice 2017–50, 2017–41 I.R.B. 280, respectively. 24-MONTH AVERAGE CORPORATE BOND SEGMENT RATES The three 24-month average corporate bond segment rates applicable for December 2017 without adjustment for the 25-year average segment rate limits are as follows: 24-Mo…
  8. T.C. Memo. 2023-141 — Danielle Monique Scott v. Commissioner
    IRCCourt RulingsNov 28, 2023related by meaning
    …ioner did not respond t o our Order by the October 2, 2023, deadline or subsequently. Discussion I. Summary Judgment The purpose of summary judgment is to expedite litigation and avoid costly, time-consuming, and unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). T he Court may grant summar…
  9. 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…
  10. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    … additions to tax and the penalties . Currently before the Court is respondent’s Motion for Partial Summary Judgment . H e seeks a ruling that section 4973 impo ses a “ tax , ” not a “penalty” to which the provisions of section 6751 (b) c ould appl y . We a gree with respondent and w ill accordingly grant his Motion. B…
  11. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019related by meaning
    made by the parties and, to the extent they are not addressed herein, we find them to be moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered under Rule 155.
  12. Notice 2017-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2017 used under § 417(e)(3)(D), the 24-m…
    IRCNoticesMay 30, 2017
    EMPLOYEE PLANS Notice 2017–31 Notice 2017–31 This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for May 2017 used under § 417(e)(3)(D), the 24-month average segment rates applicable for May 2017, and the 30-year Treasury rates. These rates reflect the applicat…
  13. 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.…
  14. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    and a decision may be rendered as a matter of law. Rule 121(b); Sundstrand Corp. , 98 T.C. at 520. In deciding whether to grant sum mary judgment, we construe factual materials and inferences drawn from them in the light most favorable to the nonmoving party (here respondent) . Sundstrand 4 On December 13, 2021, petit…
  15. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    T.C. Summary Opinion 2013-51 UNITED STATES TAX COURT MARTIN TOOMBS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27665-10S. Filed June 25, 2013. James O. Creech III, for petitioner. Thomas D. Yang, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the p…
  16. 164 T.C. No. 9 — Facebook, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsMay 22, 2025related by meaning
    Treas. Reg. § 1.482-7T(i)(6) does not operate as a safe harbor and therefore does not preclude R from making a PCT allocation under paragraph (i)(3). 6. Held, further, R did not abuse his discretion under I.R.C. § 482 by adjusting P’s and S’s RAB shares to determine the required CST p ayment. 7. Held, further, R ’s me…
  17. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    …cord before the Court was inconsistent with the reasons set forth in the denial and did not support summary judgment. W e have denied petitioner’s motion to compel production of documents and now will grant the Commissioner’s motion and sustain the IRS’s determination. Background The following facts are derived from th…
  18. T.C. Summary Opinion 2005-62 — Thomas Richard & Donna Estes White v. Commissioner
    IRCCourt RulingsMay 23, 2005related by meaning
    ’ position, we are constrained to sustain respondent’s determination on this issue. Reviewed and adopted as the report of the Small Tax Case Division. To reflect our disposition of the disputed issue, as well as petitioners’ concession, see supra note 2, Decision will be entered for respondent.
  19. Notice 2017-45 — The notice extends temporary relief under Notice 2014–5 from section 401(a)(4) nondiscrimination testing for closed defined benefit plans through plan years be…
    IRCNoticesSep 18, 2017
    EXEMPT ORGANIZATIONS Announcement 2017–12 Announcement 2017–12 Revocation of IRC 501(c)(3) Organizations for failure to meet the code section requirements. Contributions made to the organizations by individual donors are no longer deductible under IRC 170(b)(1)(A). EMPLOYEE PLANS Notice 2017–45 Notice 2017–45 The notic…
  20. 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. …