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63 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 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…
  3. 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…
  4. 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)…
  5. 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…
  6. 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…
  7. 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…
  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. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    T.C. Memo. 1996-502 UNITED STATES TAX COURT ELAINE S. BENNETT, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8545-96. Filed November 7, 1996. Vernon E. Robbins , for petitioner. Alan R. Peregoy , for respondent. MEMORANDUM OPINION DAWSON, Judge : This case was assigned to Special Trial Judge Ro…
  11. 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 (…
  12. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    …reply brief includes 4-½ pages of objections to respondent's proposed findings of fact. Id . I. The Memorandum Opinion In T.C. Memo. 1995-492, filed October 11, 1995, the Court decided the present case. In our memorandum opinion, we rejected petitioners' argument that petitioner's Transfer Refund had not been received …
  13. 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
  14. 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…
  15. 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…
  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. 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,…
  19. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    …red by the Joint Committee on Taxation (the Blue Book); privatd letter rulings and technical advice memoranda issued after October 31, 1976; actions on decisions and general counsel memoranda issued after March 12, 1981 (as well as general counsel memoranda published in pre-1955 volumes of the Cumulative Bulletin); Int…
  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…