IRCCourt RulingsFeb 9, 2023related by meaning
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 …
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 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,…
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…
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…
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 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 (…
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 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 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 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.…
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 RulingsOct 3, 1989related by meaning
e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
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 RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
IRCCourt RulingsMar 20, 1997related by meaning
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…
IRCCourt RulingsAug 8, 1996related by meaning
…96, we lack jurisdiction to abate
- 8 -
interest herein. See Commissioner v. McCoy
, 484 U.S. 3, 7
(1987); 508 Clinton Street Corp. v. Commissioner
, 89 T.C. 352,
354 (1987).
Decision will be entered for
respondent with respect to the
deficiency, including the
additional tax under sec. 72(t),
and decision will be enter…
IRCCourt RulingsMay 19, 1994
…ollowing dissolution of the corporation on December 31, 1986, plan 1 was terminated on November 10, 1987, and the assets of the trust associated with plan 1 were distributed to plan participants, including petitioners. Within 60 days, petitioners rolled over their distributions, totaling $1,128,785.16 ($1,110,300.24 fo…