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Go to T.C. Memo. 1977-1 (not yet in the library — opens the official source)
70 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    … and June 30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M. (CCH) 1707 (a case involving tax years 1979, 1980, and 1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d 825 (5th Cir. 1996) In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
  2. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
  3. 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,…
  4. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    …urance products as an employee of Fidelity Union Life Insurance Company (Fidelity). During 1976 and 1977, petitioner operated as a sole owner and paid for the costs of operating her business as an independent insurance salesperson with Fidelity. Petitioner reported her 1976 and 1977 earnings from the sale of Fidelity i…
  5. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    …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 (…
  6. IRCCourt RulingsOct 12, 1978★ strong match
    do not deal with the operations of the plan, there is 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 comm…
  7. 82 T.C. 869; 82 T.C. No. 67 — Winger's Dep't Store, Inc. v. Commissioner
    IRCCourt RulingsJun 4, 1984
    …pension plan checking account at Security Pacific National Bank, Davis, Calif. On or about June 20, 1977, petitioner issued a check in the amount of $52,941.41 to its pension plan as its employer pension contribution for the 1976 year. This check was deposited in the pension plan checking account at Security Pacific Na…
  8. Treas. Reg. § 1.501(h)-3(e) — Lobbying or grass roots expenditures normally in excess of ceiling amount.
    IRCRegulationsJul 12, 2016
    …oceeds to determine, under (b)(1), whether it is denied exemption. Y's grass roots expenditures for 1977 and 1978 ($65,000) did not exceed 150 percent of the sum of its grass roots nontaxable amounts for those years ($103,125). Y's lobbying expenditures for 1977 and 1978 ($406,750) did not exceed 150% of its lobbying n…
  9. IRCCourt RulingsJul 23, 1981
    number of separate "trades of securities” executed by petitioner during 1977 exceeded 450 and such trades involved, on a gross basis, over $3 million. On his joint Federal income tax return for 1977, petitioner reported net short-term capital gain of $13,065.06, consisting of short-term capital gains from stock transac…
  10. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984
    butions for petitioner were made to the plan. The plan was not a qualified plan on July 1, 1977, when the $21,077 distribution was made to petitioner. Petitioner did not report as income for 1977 any part of the $21,077 that was distributed to him in that year. Also during 1977, petitioner’s IRA earned $759 in interest…
  11. 71 T.C. 824; 1 Employee Benefits Cas. (BNA) 2016 — Tamko Asphalt Products, Inc. v. Commissioner
    IRCCourt RulingsFeb 15, 1979★ strong match
    …the information that petitioner furnished respondent, he made a proposed determination on April 12, 1977, that petitioner’s profit-sharing plan did not satisfy the requirements of section 401(a) for the tax year ending December 31, 1975. Petitioner appealed the proposed issuance of the adverse determination letter by r…
  12. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
  13. 78 T.C. 395; 78 T.C. No. 27 — Sutherland v. Commissioner
    IRCCourt RulingsMar 9, 1982
    …Rocky Mountain, a sole proprietorship wholly owned by petitioner, began business operations July 19,1977. Sutherland Lumber Co. (not to be confused with Rocky Mountain) is the sponsoring employer of both the "Sutherland Lumber Company Revised Retirement Annuity Plan” (hereafter annuity plan) and the "Sutherland Lumber …
  14. 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))…
  15. Treas. Reg. § 54.4975-11(a)(9) — “ESOP” requirements.
    IRCRegulationsDec 30, 2016
    (a)(9) (9) Transitional rules for ESOP's established before November 1, 1977. A plan established before November 1, 1977 that otherwise satisfies the provisions of this section constitutes an ESOP if it is amended by December 31, 1977, to comply from November 1, 1977 with this section even though before November 1, 197…
  16. IRCRegulationsSep 9, 2016
    …n of Earliest Base Unit Estimation Date Example Plan year (calendar year basis) 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 Plan A V V V V Contract 1 E/B E/B E/B E/B Base unit estimation date 1 1973 1973 1973 1976 1976 1979 1979 1979 1979 Plan B V V V V Contract 2 2 2 2 B* E/B E/B* Contract 3 E/B E/B E/…
  17. 85 FR 2292 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2020
    ERISAFinal Rules (FR)Jan 15, 2020
    …to nearest dollar) Max penalty (rounded to nearest dollar) MSHA Federal Mine Safety & Health Act of 1977 Regular Assessment 30 CFR 100.3(a) $72,620 $73,901 ( printed page 2300) MSHA Federal Mine Safety & Health Act of 1977 Penalty Conversion Table 30 CFR 100.3(g) $135 $72,620 $137 $73,901 MSHA Federal Mine Safety & Hea…
  18. 82 FR 5373 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Annual Adjustments for 2017
    ERISAFinal Rules (FR)Jan 18, 2017
    …to nearest dollar) Max penalty (rounded to nearest dollar) MSHA Federal Mine Safety & Health Act of 1977 Regular Assessment 30 CFR 100.3(A) $68,300 $69,417. MSHA Federal Mine Safety & Health Act of 1977 Penalty Conversion Table 30 CFR 100.3(G) $127 68,300 $129 69,417. MSHA Federal Mine Safety & Health Act of 1977 Minim…
  19. 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…
  20. 107 T.C. No. 1 — Lucky Stores, Inc., and Subsidiaries v. Commissioner
    IRCCourt RulingsAug 6, 1996related by meaning
    …y with Rev. Rul. 76-28, supra , but also with the administrative position taken in Technical Advice Memorandum 8210014 (TAM) and in a series of private letter rulings. Respondent points out that section 6110(j)(3) prohibits using or