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…
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…
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…
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…
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))…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
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 …
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…
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 …
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…
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.…
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…
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 (…
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…
IRCCourt RulingsOct 3, 1995related by meaning
…ion qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as part of th…
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…
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 …
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…
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 …
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …