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76 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …that it included the amendments made on January 22 and 29, 1969. 26 C.F.R. sec. 1.482-2 (1970). The 1971 revision of the Code of Federal Regulations codifi e d regulations as of January 1, 1971, including ame ndments published during 1970. See 26 (p art 1 (secs. 1.401-1.500)) C.F.R. i, v (1971). This 1971 revision cont…
  2. 67 T.C. 878 — Blyler v. Commissioner
    IRCCourt RulingsFeb 28, 1977
    pril 1, 1971, and since that time he has not been employed by either Howe & French, Inc., or Landsverk Corp. or any of its subsidiaries or affiliates. In January 1971 petitioner learned that the pension trust was to be terminated due to the decline in profits of Howe & French, Inc., and Landsverk. Upon application (app…
  3. 63 T.C. 386 — Estate of Stefanowski v. Commissioner
    IRCCourt RulingsDec 19, 1974
    …n Fund A. These items were sold and the proceeds reinvested in short-term Treasury bills by March 1,1971. On March 25, 1971, the trustees of the plan made a pro rata cash distribution of all the assets of the plan to the participants or their beneficiaries. Petitioner, as decedent’s designated beneficiary (section 9 of…
  4. 69 T.C. 97 — Feroleto Steel Co. v. Commissioner
    IRCCourt RulingsOct 25, 1977
    …payments of Payments of repayment principal interest Dec. 1969.0 $2,656 Dec. 1970.0 10,625 Dec. 28, 1971 .$125,000 10,625 125,000 23,906 Late in 1971 the trustees asked Mr. Smith to ascertain from Seaboard the amount of repayment of the loan and the possibility of repaying the loan over a period of four quarters. Mr. S…
  5. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1 Unless otherwise indicated, all section references are to (continued...) T.C. Memo. 1999-199 UNITED STATES TAX COURT DON LAVERNE CLARKE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 151-97. Filed June 18, 1999. Don Laverne Clarke, pro se. Anthony Hoefer , for respondent. MEMORANDUM FINDINGS …
  6. 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))…
  7. 73 T.C. 779 — Woodson v. Commissioner
    IRCCourt RulingsFeb 5, 1980
    . Woodson, deceased. Petitioners filed their joint Federal income tax return for 1971 with the Director, Internal Revenue Service Center, Austin, Tex. Curtis B. Woodson and Edna Woodson, married in 1973, filed joint income tax returns for 1973 and 1974 with the Director, Internal Revenue Service Center, Austin, Tex. On…
  8. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …rement interest 5% 5% 5% Salary scale -0--0--0- Pre-retirement turnover -0--0--0- Mortality (males) 1971 IAM-2 1971 IAM-2 1971 IAM-2 Mortality (females) 1971 IAM-8 1971 IAM-8 1971 IAM-8 Form of benefit , , For purposes of these calculations, Matthews used the following data for Davis: Date of birth . 5/7/34 Date of spo…
  9. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
  10. 67 T.C. 906 — Jennemann v. Commissioner
    IRCCourt RulingsMar 7, 1977
    OPINION Hall, Judge: Respondent determined a $557.91 deficiency in petitioners’ 1971 income tax. The issues for decision are: (1) Whether this Court is prohibited from taking action herein since it is not established pursuant to the provisions of article III of the Constitution. (2) Whether section 402(a)(2) as applica…
  11. IRCRegulationsMay 18, 2016
    …ality Table (1983 IAM) (Female); the 1983 Individual Annuity Mortality Table (1983 IAM) (Male); the 1971 Group Annuity Mortality Table (1971 GAM) (Female); the 1971 Group Annuity Mortality Table (1971 GAM) (Male); the 1971 Individual Annuity Mortality Table (1971 IAM) (Female); or the 1971 Individual Annuity Mortality …
  12. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    IRCCourt RulingsDec 30, 1998
    …t respondent has agreed to. The claimed costs and improvements still in dispute relate to the years 1971 through 1986, for which petitioner has minimal or no documentation. Respondent argues that petitioner's testimony as to the costs of the claimed improvements is self-serving and uncorroborated. Petitioner claims tha…
  13. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    …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 (…
  14. 70 T.C. 158 — Ma-Tran Corp. v. Commissioner
    IRCCourt RulingsMay 4, 1978
    …ar 1973 he submitted vouchers covering $7,569.14 and charged back $2,050. During the calendar years 1971, 1972, and 1973 Huffaker received advances for travel and entertainment expenses and submitted vouchers for travel and entertainment expenses as follows: Year Advances Vouchers Difference 1971 .$6,900 $4,305.55 $2,5…
  15. IRCCourt RulingsJun 13, 1977
    …related instructions from Williams or anyone else at Staff. From the time she was hired in February 1971 until December of that year, Fowler received her paychecks from Staff. The Crockett corporation’s fiscal year ended July 31, and, in order to be eligible for its pension and profit-sharing plans, an employee had to …
  16. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
  17. 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 .…
  18. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    …(1990), on appeal (Fed. Cir., Nov. 1, 1990). The Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, 104 Stat. 1388, while maintaining this option for a severely limited class of eligible individuals, suspended it for 5 years for the vast majority of CSRS employees. The portion of sec. 72(e) involved herein rea…
  19. 68 T.C. 433 — Newman v. Commissioner
    IRCCourt RulingsJun 29, 1977
    …tt, Judge: Respondent determined deficiencies in petitioners’ Federal income tax for calendar years 1971 and 1972 of $1,133.25 and $3,503.18, respectively. The sole issue for decision is whether an amount received by petitioners from an annuity under the New York State Employees’ Retirement System equal to the interest…
  20. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsMar 3, 2000related by meaning
    …C:EBEO:4 TL-N-4712-99 UILC: 419.00-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR FROM: Assistant Chief Counsel (Employee Benefits and Exempt Organizations) CC: EBEO SUBJECT: This Field Service Advice is in res ponse to your memorandum dated October 5, 1999. Field Service Advice is not …