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69 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    lieved that the executive branch should conduct a comprehensive study of the 1968 regulations, and that the executive branch should carefully consider whether the 1968 regulations should be modified “in any respect.” H.R. Conf. Rept. No. 99-841 (Vol. II), at II - 638 , 1986- 3 C.B. (Vol. 4) at 638. Petitioner has a con…
  2. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    …America/Bradley partners' capital accounts decreased from a deficit of $996,674 at the beginning of 1987 to a deficit of $2,853,708 at the end of 1987. During 1987, Mr. Bach assigned his entire interest in - 4 - 4 Although the exact date that Mr. Bach assigned his interest in America/Bradley to Mr. Goldstein is not cle…
  3. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    June 30, 1987, for employees covered under a collective bargaining agreement were included in the $3,210,000 contribution for union medical benefits. Petitioner's 1987 contribution included $9,022,227 for incurred but unpaid medical, dental, and short-term disability benefits. Postretirement Benefits--Retirees Reserve…
  4. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …ks stamped with the signature of Andrew Bryen (Andrew Bryen physically signed three W & A checks in 1987). One of the employees paid with W & A checks was Loretta Wilcox, a secretary with Machise. She had been hired by Bucci in September 1980, after she had filled out a formal employment - 86 - application. She could n…
  5. 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,…
  6. T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers …
    IRCTreasury DecisionsSep 29, 2003related by meaning
    rders) applies for transfers, distributions, and payments made after December 31, 2001. Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows: Authority: 26 U.S.C. 7805. Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
  7. Treas. Reg. § 1.419-1T(b3)(3) — Treatment of welfare benefit funds. (Temporary)
    IRCRegulationsSep 9, 2016
    …welfare benefit fund with a taxable year ending January 31. During its taxable year ending June 30, 1987, and on or before January 31, 1987, the employer contributes $250,000 to the fund, and during the remaining portion of its taxable year ending June 30, 1987, the employer contributes $200,000. The qualified direct c…
  8. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018
    …d only for clear error on appeal), aff'g in part, rev'g in part 89 T.C. 1229 (1987), and aff'g T.C. Memo. 1987-625, T.C. Memo. 1987-626, and T.C. Memo. 1987-628; but see Sacks v. Commissioner, 69 F.3d 982, 986 (9th Cir. 1995) (determination that transaction a sham is reviewed for clear error on underlying facts and de …
  9. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    IRCCourt RulingsSep 3, 1998★ strong match
    …his Court under substantially identical circumstances. See Steel Balls, Inc. v. Commissioner , T.C. Memo. 1995-266, affd. without published opinion 89 F.3d 841 (8th Cir. 1996). 6 We rejected the same argument presented herein and concluded that respondent's position was clearly supported by the statute and regulations.…
  10. T.C. Memo. 1998-64 — Reed Smith Shaw & McClay; William J. Smith, Tax Matters Partner v. Commissioner
    IRCCourt RulingsFeb 17, 1998
    or the period beginning March 28, 1987, and ending April 24, 1987, reports that on April 15, 1987, 4,000 shares of stock of Saztec International, Inc. (Saztec), were sold for $31,998 or $8 per share, and on April 23, 1987, another 500 shares of Saztec stock were sold for $3,973 or $8 per share. Saztec was publicly trad…
  11. 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))…
  12. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    , 1987, and 1988, which were included in the application, were as follows: 1986 1987 1988 Anticipated contribution $33,788,071 $39,519,000 $37,000,000 Investment income 1,084,333 1,264,000 1,184,000 Total projected income 34,872,404 40,783,000 38,184,000 Anticipated expenses 29,303,726 32,800,000 36,736,000 Projected s…
  13. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997
    …lso stipulated an increase, pursuant to section 419A(f)(7), in the amount of $432,010. Petitioner's 1987 VEBA Trust Contribution Pursuant to an amendment to the VEBA Trust agreement on December 29, 1987, employee welfare benefits for collectively bargained employees ceased to be funded through the VEBA Trust and were t…
  14. 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…
  15. 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 (…
  16. T.C. Memo. 2003-32 — Howard E. Clendenen v. Commissioner
    IRCCourt RulingsFeb 12, 2003related by meaning
    …ovided calculations to establish that the plan was qualified as of the taxable year ending June 30, 1987. In their calculations, petitioners have ignored findings from the declaratory judgment; i.e., $30,000 treated as an employee - 11 - contribution and $9,000 treated as an employer contribution for taxable year ended…
  17. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …0 05/01/1986 10/01/1986 7.75 10/01/1986 11/01/1986 7.50 11/01/1986 12/01/1986 7.75 12/01/1986 03/01/1987 7.50 03/01/1987 06/01/1987 7.25 06/01/1987 07/01/1987 7.50 07/01/1987 10/01/1987 7.75 10/01/1987 11/01/1987 8.00 11/01/1987 03/01/1988 8.25 03/01/1988 04/01/1988 8.00 04/01/1988 06/01/1988 7.75 06/01/1988 09/01/1988…
  18. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997
    x 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661(a) 1987 $7,348-367 1 - 1988 29,345 2,935 1,467-7,336 1 50 percent of the interest due on the deficiency. Unless otherwise indicated, all section and Code references are to the Internal Revenue Code as in effect for the years in issue, and all Rule references are to the Tax …
  19. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. RICHARD L. SMITH and SMITH ADMINISTRATORS
    ERISACourt RulingsJan 20, 1998
    m February 23, 1987 to August 23, 1987 at an interest rate of 5.625%. Ex. C21. 8CD No. 11813-17420 was issued on July 20, 1987 and reached maturity on October 19, 1987; the CD paid 6.50% annual interest. Ex. C30. Once SA paid off Loan Nos. 25-20129-4 and 25-20148-4, CD Nos. 346 and 350 ceased to be collateralized. 9CD …
  20. 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…