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. 1989-86 (not yet in the library — opens the official source)
58 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 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…
  2. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
  3. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
  4. T.C. Memo. 1998-216 — Estate of Suzanne W. Cullison, Deceased; J. Greg Cullison, Personal Representative v. Commissioner
    IRCCourt RulingsJun 17, 1998
    …10, 1988, the IRS published temporary guidance to taxpayers for transfers occurring after April 30, 1989, that would be subject to section 7520. Notice 89-24, 1989-1 C.B. 660, published on March 6, 1989, sets forth the formulas for computing the present value of an annuity on the basis of the appropriate applicable Fed…
  5. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996★ strong match
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  6. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    IRCCourt RulingsOct 29, 2002
    ing in 1989. The NYSL did not offer petitioner the option of receiving a lump-sum payment in 1989. Petitioner was employed by the Consulate General of Nigeria when he won the lottery. He used the cash method of accounting in 1989. Petitioner received two or three offers to buy the rights to his future lottery winnings …
  7. 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 (…
  8. 103 T.C. 200; 103 T.C. No. 13 — Rubin v. Commissioner
    IRCCourt RulingsAug 15, 1994
    …est was signed by Samuel J. Sirota, an attorney and a certified public accountant, on September 15, 1989. On September 15, 1989, the corporation timely filed its Federal income tax return, Form 1120S, for its taxable year ended June 30, 1989. The corporation did not claim a deduction for the contributions, if any, it m…
  9. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    …executive compensation of CEO's by industry categories as of May 1990, showing results for the year 1989 classified under all industries and categories of industries for companies that had sales of approximately $162 million: Title Year Sales Average +1 SD +2 SDs All Industries CEO 1989 $162.416 $340.72 $497.96 $655.21…
  10. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …61 F.2d 494 (7th Cir. 1988), affd. sub nom. Ratliff v. Commissioner , 865 F.2d 97 (6th Cir. - 125 - 1989), affd. sub nom. Kirchman v. Commissioner , 862 F.2d 1486 (11th Cir. 1989), Killingsworth v. Commissioner , 864 F.2d 1214 (5th Cir. 1989); affd. sub nom. Keane v. Commissioner , 865 F.2d 1088 (9th Cir. 1989), affd. …
  11. 109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner
    IRCCourt RulingsDec 29, 1997
    … of the property pursuant to the 1989 Manual. - 7 - In November 1989, the Corps also entered into a Memorandum of Agreement (MOA) with the EPA that establishes the procedures to be used by the Corps staff in reviewing section 67(a) (section 404) CWA permit applications. Specifically, the MOA articulated
  12. T.C. Memo. 1998-388 — Robert B. Keenan v. Commissioner
    IRCCourt RulingsNov 2, 1998
    … findings of fact and opinion with respect to each issue. Issue 1. Statutory Period of Limitations--1989 Petitioner asserts that he timely filed a 1989 tax return and therefore maintains that the period for assessing a deficiency and additions to tax against him for 1989 expired before the date on which respondent mail…
  13. 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
    …g annual rates were applicable during the course of this transaction: December 1988, 8.40%; January 1989, 9.01%; February, 9.30%; March, 9.30%; April, 9.62%; May, 9.82%; June, 9.39%; July, 8.86%; August, 8.34%; September, 8.07%; and October, 8.45%. The average annual rate over this period was 8.96%. This is the rate I …
  14. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    …reply brief includes 4-½ pages of objections to respondent's proposed findings of fact. Id . I. The Memorandum Opinion In T.C. Memo. 1995-492, filed October 11, 1995, the Court decided the present case. In our memorandum opinion, we rejected petitioners' argument that petitioner's Transfer Refund had not been received …
  15. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …ns of petitioners herein. Lerch v. Commissioner , 877 F.2d 624, 631-632 (7th Cir. 1989), affg. T.C. Memo. 1987-295; Geiger v. Commissioner , 440 F.2d 688, 689-690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159. The determination of respondent is sustained as to rental expenses claimed in 1989 and 1990. Issue 7. …
  16. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …0 04/01/1988 06/01/1988 7.75 06/01/1988 09/01/1988 8.00 09/01/1988 11/01/1988 8.25 11/01/1988 04/01/1989 7.75 04/01/1989 06/01/1989 8.00 06/01/1989 08/01/1989 7.75 08/01/1989 09/01/1989 7.50 09/01/1989 10/01/1989 7.25 10/01/1989 12/01/1989 7.50 12/01/1989 03/01/1990 7.25 03/01/1990 06/01/1990 7.50 06/01/1990 07/01/1990…
  17. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
  18. T.C. Memo. 2012-300 — Churchill, LTD. Employee Stock Ownership Plan & Trust v. Commissioner
    IRCCourt RulingsOct 25, 2012
    …spondent issued a favorable determination letter. The plan was amended and restated on November 18, 1989 (1989 plan), effective for the fiscal year beginning July 1, 1989. The 1989 plan was amended on June 23, 1997, and June 5, 1998. On September 13, 2001, the 1989 plan was amended and restated (2001 plan). The 1989 pl…
  19. Treas. Reg. § 1.411(a)-6(d) — Year of service; hours of service; breaks in service.
    IRCRegulationsSep 9, 2016
    …1988: Employee A incurs 4 consecutive one-year breaks in service during the years 1985 through 1988.1989: Employee A's pre-1989 service is disregarded in 1989 and all subsequent plan years because his years of service as of January 1, 1989, equal the number of consecutive one-year breaks he has incurred as of that date…
  20. 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))…