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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. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
   IRCCourt RulingsMar 5, 1987★ strong match
   … Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts with effective dates during 1980 and 1981; Act of October 10, 1980, Pub. L. 96-417, tit. V, sec. 501(9), 94 Stat. 1727, 1742 (effective Nov. 1, 1980)…
3. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
   IRCCourt RulingsDec 19, 2000★ strong match
   …etermined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice of deficiency was not an affected items notice…
4. 85 T.C. 869; 85 T.C. No. 51 — Griswold v. Commissioner
   IRCCourt RulingsNov 26, 1985
   …tion of these principles to the facts of the instant case requires a holding for respondent. During 1980, petitioner was the owner of an annuity contract with John Hancock. On July 1, 1980, petitioner obtained a loan from John Hancock by borrowing against the loan value of the annuity contract. At the time of such borr…
5. 29 C.F.R. § 2510.3-2(g)(5) — Employee pension benefit plan
   ERISARegulationsJun 15, 2018
   …this paragraph (g) works. As referred to in these examples, the CPIU's for July through November of 1980 are as follows: July 1980: 247.8 August 1980: 249.4 September 1980: 251.7 October 1980: 253.9 November 1980: 256.2 Example (1)(a).E is an employer. R received monthly benefits of $600 under a straight-life annuity u…
6. 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 (…
7. Treas. Reg. § 1.501(h)-3(e) — Lobbying or grass roots expenditures normally in excess of ceiling amount.
   IRCRegulationsJul 12, 2016
   ection 4911(a) is $5,000 {25% × ($100,000−$80,000) = $5,000}. For 1980, the tax is $10,000. For 1981, the tax is $1,250. (3) The taxable years 1979 through 1981 are all determination years under paragraph (c)(8) of this section. On its annual return for determination year 1979, the first year of its first election, X c…
8. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
   IRCCourt RulingsOct 3, 1995★ strong match
   …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10066-93. Filed October 3, 1995. Harold L. Humberson, pro se. Alan R. Pere…
9. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
   IRCCourt RulingsSep 25, 1996
   …Petitioner Crescenzo's Deduction of MIT 80 Partnership Loss On his individual income tax return for 1980, Dr. Crescenzo reported a Schedule E partnership loss from MIT 80 of $140,472, representing his 6.25-percent share of the loss purportedly incurred in 1980 by the MIT 80 partnership. Respondent has issued a statutor…
10. 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,…
11. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989★ strong match
    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…
12. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …5 03/01/1979 06/01/1979 7.50 06/01/1979 09/01/1979 7.50 09/01/1979 12/01/1979 7.75 12/01/1979 03/01/1980 8.50 03/01/1980 06/01/1980 8.75 06/01/1980 09/01/1980 8.75 09/01/1980 12/01/1980 9.00 12/01/1980 01/01/1981 9.25 01/01/1981
13. 78 T.C. 86; 78 T.C. No. 6 — Horvath v. Commissioner
    IRCCourt RulingsJan 20, 1982
    …. 1088 (1979), the EG & G plan is not a qualified plan. See, e.g., Leightweis v. Commissioner, T.C. Memo. 1980-290; Andalman v. Commissioner, T.C. Memo. 1980-276; Alexander v. Commissioner, T.C. Memo. 1980-71. In the cited cases, the taxpayers were active participants in qualified plans during part of their taxable yea…
14. 29 C.F.R. § 2530.200b-4(b)(4)(i)(A) — One-year break in service.
    ERISARegulationsJan 1, 2017
    …ompletes 800 hours of service during the remainder of 1979 and 600 hours of service from January 1, 1980 through May 31, 1980. Under paragraph (b)(1)(iii) of this section, A's reemployment commencement date is June 1, 1979. By June 1, 1980, A has completed a year of service during the eligibility computation period fol…
15. 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))…
16. Treas. Reg. § 1.219-2(h) — Definition of active participant.
    IRCRegulationsApr 14, 2016
    …ice. The plan year is the calendar year. B, a calendar-year taxpayer, enters the plan on January 2, 1980, when he is 27 years of age. Since B has attained the age of 25, he is a participant in the plan. However, B completes less than 1,000 hours of service in 1980 and 1981. Although B is not accruing any benefits under…
17. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
18. 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 …
19. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
20. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…