Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to T.C. Memo. 1983-733 (not yet in the library — opens the official source)
73 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    arties at the original contract date.” Notice 88-123, 1988- 2 C.B. at 477. 145 JJ. T he 1988 amendment to section 7805 regarding temporary regulations In 1988, Congress added section 7805(e), which provided: SEC. 7805 (e). Temporary Regulations. -- (1) Issuance. --Any temporary regulation issued by the Secretary shall …
  2. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …t to BBPA of professional fees of $14,366. Tax Deductions On their individual income tax return for 1983, the 25 participants in MIT 83 reported Schedule E partnership losses from MIT 83 in proportion to their interests in the partnership. Respondent issued a notice of final partnership administrative adjustment to MIT…
  3. 93 T.C. 114; 93 T.C. No. 12 — Wood v. Commissioner
    IRCCourt RulingsJul 31, 1989
    …find this to be a non sequitur. The admittedly proper partial rollover was recorded on September 8, 1983. The 60-day rollover period expired on September 12, 1983. The first monthly statement after these events was for the period ended September 30, 1983. If petitioner had failed to actually transfer the lump-sum distr…
  4. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …Post-retirement interest 5% 5% Salary scale 4% -0- Pre-retirement turnover -0--0- Mortality (males) 1983 IAM-4 1983 IAM-4 Mortality (females) 1983 IAM-10 1983 IAM-10 Form of benefit , For purposes of these calculations, Matthews used the following data for the Foxes: Jonathan Fox Renee Fox Date of birth 2/2/53 2/20/52
  5. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997★ strong match
    …rook were performed at the office of Dura-Craft by employees of DuraCraft. A. Loans On February 10, 1983, the Chapmans and the Christies each requested a loan in the amount of $37,500 from the Dura-Craft Profit-Sharing Plan (Plan) to meet unspecified "emergency financial requirements". On February 22, 1983, the Chapman…
  6. 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,…
  7. 92 T.C. 291; 92 T.C. No. 16 — D.J. Lee, M.D., Inc. v. Commissioner
    IRCCourt RulingsFeb 7, 1989
    …the plans’ funding. No further withdrawals from the extra checking account were made until July 15, 1983, as described below. On April 20, 1983, petitioner applied for an extension of time in which to file the plans’ annual returns for the year in issue. Thereafter, acting on the consultants’ advice that the contributi…
  8. 104 T.C. 559; 104 T.C. No. 28 — National Presto Indus. v. Commissioner
    IRCCourt RulingsMay 3, 1995
    …r the taxable year 1987. The financial statements of the National Presto VEBA for the taxable years 1983, 1984, and 1985 state that, for those years, the VEBA did not have investment income because “the Plans fund benefits paid and expenses as incurred”. (Emphasis supplied.) At the close of each of the taxable years 19…
  9. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    …etermination letters shall have limited application * * * See also Vernaccini v. Commissioner, T.C. Memo. 1974-66. Some of the cited cases raise the question of the application of secs. 165(a) and 23(p), I.R.C. 1939, to a determination of the proper effective date of trust instruments adopted by accrual basis taxpayers…
  10. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …8/01/1982 10/01/1982 11.00 10/01/1982 11/01/1982 10.75 11/01/1982 12/01/1982 10.50 12/01/1982 01/01/1983 10.25 01/01/1983 02/01/1983 10.00 02/01/1983 04/01/1983 9.75 04/01/1983 06/01/1983 9.50 06/01/1983 09/01/1983 9.25 09/01/1983 02/01/1984 9.50 02/01/1984 03/01/1984 9.75 03/01/1984 04/01/1984 9.50 04/01/1984 05/01/19…
  11. IRCRegulationsMay 18, 2016
    …andard mortality table means one of the following tables: the UP-1984 Mortality Table (Unisex); the 1983 Group Annuity Mortality Table (1983 GAM) (Female); the 1983 Group Annuity Mortality Table (1983 GAM) (Male); the 1983 Individual Annuity Mortality Table (1983 IAM) (Female); the 1983 Individual Annuity Mortality Tab…
  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. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    …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 (…
  14. PLR 199934002 — Deferred Compensation
    IRCPrivate Letter RulingsAug 27, 1999related by meaning
    …Number: 199934002 Release Date: 8/27/1999 INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM Taxpayer's Name: Taxpayer's Address: Taxpayer's Ident. No.: Taxable Years at Issue: Date of Conference: Legend : Taxpayer = Plan = Trust Agreement = ISSUES : (1) Whether, under the rules of section 461 of the …
  15. 81 FR 47534 — Proposed Revision of Annual Information Return/Reports
    ERISAProposed Rules (FR)Proposed Jul 21, 2016
    …ty 1 1971 Group Annuity Mortality (G.A.M.) 2 1971 Individual Annuity Mortality (I.A.M.) 3 UP-1984 4 1983 I.A.M 5 1983 G.A.M 6 1983 G.A.M. (solely per Rev. Rul. 95-28) 7 UP-1994 8 Mortality table applicable to current plan year under section 1.431(c)(6)-1 of the Income Tax Regulations 9 RP-2000 10 RP-2000 (with Blue Col…
  16. T.C. Memo. 1998-172 — Richard S. & Bernice F. Roberts v. Commissioner
    IRCCourt RulingsMay 11, 1998
    …d is irrelevant under the statutory scheme for taxation of such benefits. Section 86 was enacted in 1983. Social Security Amendments of 1983, Pub. L. 98-21, sec. 121(a), 97 Stat. 80. This provision - 3 - reversed a longstanding practice of excluding Social Security benefits from income. See S. Rept. 98-23, at 25 (1983)…
  17. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    motion for costs was filed out of time and should be "dismissed" for that reason. We reject respondent's contention and do not consider it further. 12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is generally applicable to proceedings commenced after …
  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. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  20. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017
    …tory, creating no legally enforceable rights for taxpayers. See, e.g., Greene v. Commissioner, T.C. Memo. 1992-202, 1992 Tax Ct. Memo LEXIS 239; Tucker v. Commissioner, T.C. Memo. 1983-210, 1983 Tax Ct. Memo LEXIS 578; Chapman v. Commissioner, T.C. Memo. 1982-68, 1982 Tax Ct. Memo LEXIS 675; see also Marks v. Commissio…