Search the Pension Law Library

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. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
   IRCCourt RulingsOct 3, 1995★ strong match
   … more equitable result. See Hildebrand v. Commissioner , 683 F.2d 57, 58 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Zadan v. Commissioner , T.C. Memo. 1993-85. After all, the power to legislate is exclusively the power of Congress and not of this Court or any other. See Iselin v. United States , 270 U.S. 245, 250 (1926…
3. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
   IRCCourt RulingsDec 19, 2000★ strong match
   …ners were liable for a $21 addition to tax under section 6659 as a result of this underpayment. The 1980 notice reflects respondent’s determination that the portion of the disallowed investment tax credit that petitioners carried back to 1980 results in an underpayment in tax of $10,331 for 1980. The 1980 notice determ…
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. 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)…
6. 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…
7. 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 (…
8. 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…
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. 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
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. 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…
13. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997★ strong match
    performed by anyone else. Discussion Petitioners bear the burden of establishing that respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a); Welch v. Helvering , 290 U.S. 111 (1933). Petitioners' briefs refer to several facts which were not included…
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. 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…
16. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    o any participant which exceed the limitations of section 415(b). Paragraph (1) of subsection (d) shall not apply for purposes of this subparagraph.”. (c) Effective Date. — The amendments made by this section shall apply to taxable years beginning after December 31, 1978. [Senate Amendment to H.R. 4961, July 23 (legisl…
17. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
18. 71 T.C. 32; 1 Employee Benefits Cas. (BNA) 2040 — Thompson v. Commissioner
    IRCCourt RulingsOct 12, 1978related by meaning
    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…
19. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
20. 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…