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1. 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…
2. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
   IRCCourt RulingsFeb 22, 1989★ strong match
   …e notes 3 and 4, supra. The salaries of Louisiana State judges are established by State statute. In 1981, Justices on the Supreme Court of Louisiana had the highest salary of all judges in the State. The salary of Louisiana Supreme Court Justices, on an annual basis, was $61,635 from January 1, 1981, through August 31,…
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. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
   IRCCourt RulingsJul 30, 1985★ strong match
   …U.S. 940 (1971). We have followed this approach in many cases. E.g., Van Sant v. Commissioner, T.C. Memo. 1984-535; Craine v. Commissioner, T.C. Memo. 1984-513; Pizor v. Commissioner, T.C. Memo. 1979-487; Kacin v. Commissioner, T.C. Memo. 1979-410; Cooper v. Commissioner, T.C. Memo. 1979-256. See also Day v. Commission…
5. 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))…
6. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
   IRCCourt RulingsDec 19, 2000★ strong match
   …s were liable for a $3,099 addition to tax under section 6659 as a result of this underpayment. The 1981 notice reflects respondent’s determination that the portion of the disallowed investment tax credit that petitioners carried back to 1981 results in an underpayment in tax of $1,926 for 1981. The 1981 notice determi…
7. 95 T.C. 289; 95 T.C. No. 22 — Estate of Levitt v. Commissioner
   IRCCourt RulingsSep 13, 1990
   …al rule is to prevent an unintended testamentary disposition in wills executed before September 12, 1981, that contain a maximum marital deduction "formula clause." Congress was concerned that formula clauses in wills drafted prior to 1981 could operate to make the marital deduction applicable to the entire adjusted gr…
8. 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 (…
9. Treas. Reg. § 1.410(b)-7(c)(4)(i)(D) — Definition of plan and rules governing plan disaggregation and aggregation.
   IRCRegulationsSep 9, 2016
   ce 1989 and worked for Division M from 1981 to 1988. Employee C has worked in the headquarters of Employer X since 1981. For the period 1981 to 1988 Employee C was credited with years of service under Plan P. (b) For purposes of the benefits accrued by Employee A under Plan P during years 1981 through 1997, Employee A …
10. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987
    …130,000 from the trust. The note was payable on demand and was non-interest-bearing. On January 30, 1981, an article published in the Detroit Free Press stated that the shareholders of Cunningham had approved the sale to the New York investors on January 29, 1981, and that the shareholders would receive $18 per share b…
11. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …0 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 02/01/1981 9.50 02/01/1981 04/01/1981 9.75 04/01/1981 06/01/1981 10.00 06/01/1981 07/01/1981 10.25 07/01/1981 08/01/1981 10.50 08/01/1981 10/01/1981 10.25 10/01/1981 11/01/1981 10.50 11/01/1981 12/01…
12. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983
    …ies); Moore v. Commissioner, 71 T.C. 533 (1979) (retail grocery store); Black v. Commissioner, T.C. Memo. 1983-245 (sales of developed real estate); Pilkington v. Commissioner, T.C. Memo. 1983-111 (operation of lounge); Smith v. Commissioner, T.C. Memo. 1983-93 (paint contracting business); Nelson v. Commissioner, T.C.…
13. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981
    increased to the lesser of $2,000 or 100 percent of compensation. The Economic Recovery Act of 1981, Pub. L. 97-34, sec. 311, 95 Stat. 274-283 (1981). Similarly, for taxable years beginning after 1981, the maximum contribution to a Keogh Plan is increased to the lesser of $15,000 or 15 percent of income, and the amount…
14. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
15. 91 T.C. 769; 91 T.C. No. 49 — Estate of Christmas v. Commissioner
    IRCCourt RulingsOct 6, 1988
    … forming her estate plan and the intent of Congress in enacting the unlimited marital deduction. In 1981 section 2056(c), which limited the marital deduction otherwise available under section 2056(a), was repealed by section 403(a)(1)(A) of the Economic Recovery Tax Act of 1981, Pub. L. 97-34, 95 Stat. 301, effective f…
16. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …), affd. without published opinion 578 F.2d 1383 (8th 042 Cir. 1978); Bartley v. Commissioner, T.C.·Memo. 1998-322; Ruben v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner, T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696; Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v. Commissione…
17. 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…
18. T.C. Memo. 1998-154 — Estate of Martin J. Machat, Deceased; Avril Giacobbi and Eric R. Sklar, Executors v. Commissioner
    IRCCourt RulingsApr 27, 1998
    on 314(c)(1) of the Economic Recovery Tax Act of 1981 (ERTA), Pub. L. 97-34, 95 Stat. 172, 286, provides that a distributee is taxed on benefits under a qualified retirement plan in the tax year in which those benefits are "actually distributed". Prior to the 1981 amendment, section 402(a)(1) provided that amounts held…
19. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
20. 29 C.F.R. § 2530.200b-4(b)(4)(ii) — One-year break in service.
    ERISARegulationsJan 1, 2017
    … incurs a one-year break in service. In the eligibility computation period beginning on February 1, 1981, C is not credited with an hour of service for the performance of duties until March 1, 1981. Under paragraph (b)(1)(iii) of this section, March 1, 1981 is C's reemployment commencement date. C terminates employment…