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…
T.D. 9294 — Final regulations under section 401 of the Code set forth standards for electronic systems that make use of an electronic medium to provide a notice to a recip… IRCTreasury DecisionsNov 27, 2006related by meaning
… * *
Par. 9. Section 1.7476-2 is amended by revising paragraph (c)(2) to read as follows:
§1.7476-2 Notice to interested parties.
* * * * * (c) * * *
(2) If the notice to interested parties is delivered using an electronic medium under an electronic system that satisfies the applicable notice requirements of §1.401(a)-…
Notice 2012-46 — This notice provides guidance in the form of questions and answers with respect to the notice requirements of section 101(j) of the Employee Retirement Income … IRCNoticesJul 23, 2012related by meaning
…umber for contact information].
Q-10. What are the acceptable methods of providing a section 101(j) notice?
A-10. A section 101(j) notice must be in writing and may be furnished in any paper or electronic form to the extent such form is reasonably accessible to persons to whom the notice is required to be provided. Per…
IRCCourt RulingsSep 25, 1996
… Schedule E the partnership losses
from W & A in proportion to their interests. Respondent issued a
notice of final partnership administrative adjustment to W & A,
in which respondent disallowed the entire claimed loss of
$3,586,269 for the year 1987.
In 1987, the New Jersey Department of Labor canceled the
Notice 2011-97 — This notice contains the 2011 Cumulative List of Changes in Plan Qualification Requirements (2011 Cumulative List) described in section 4 of Rev. Proc. 2007-44… IRCNoticesDec 27, 2011related by meaning
ributions. (2008 C. L.)
Notice 2007-7, 2007-1 C.B. 395, provides guidance regarding § 411(a), as amended by § 904 of PPA ’06. (2008 C. L.)
411(a)(11): PPA ’06 § 1102(a) provides that notice required to be provided under § 411(a)(11) may be provided as much as 180 days before the annuity starting date. Section 1102(b) o…
IRCCourt RulingsDec 19, 1995
…olved C in 1986 and distributed all of the assets
in the plan 1 trust to employees, including P, in 1987.
We held in Fazi v. Commissioner
, 102 T.C. 695 (1994)
(Fazi I), that plan 1 was not qualified and its related
trust was not exempt during 1985, 1986, and 1987. We
also held that, except for amounts conceded by R, P…
Rev. Proc. 2025-4 — This document updates Rev. Proc. 2024-4, 2024-1 IRB 160, relating to the types of advice the IRS provides to taxpayers on issues under the jurisdiction of the … IRCRevenue ProceduresSuperseded Dec 30, 2024related by meaning
if the notice is delivered using an electronic medium under a system that satisfies the requirements of § 1.401(a)-21.
Time when notice must be given .02 Notice must be given not less than 10 days nor more than 24 days prior to the day the application for a determination is submitted. If an applicant fails to provide …
Notice 2009-98 — Retirement plans; qualification, list of changes. This notice sets forth a list of changes referred to in Rev. Proc. 2007-44, 2007-2 C.B. 54, pertaining to the… IRCNoticesDec 28, 2009related by meaning
… Fed. Reg. 61877) setting forth standards for the use of an electronic medium to provide applicable notices to recipients or to make participant elections. (2006 C. L.).
Notice 2008-21, 2008-1 C.B. 431, provides transitional guidance for 2008 under § 436 for small plans with end-of-year valuation dates. (2008 C. L.).
N…
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…
Notice 2010-90 — This notice contains the 2010 Cumulative List of Changes in Plan Qualification Requirements (2010 Cumulative List) described in section 4 of Rev. Proc. 2007-44… IRCNoticesDec 27, 2010related by meaning
mall plans with end-of-year valuation dates. (2008 C. L.).
Notice 2008-73, 2008-2 C.B. 717, expands transition relief of Notice 2008-21. (2008 C. L.). Rev. Rul. 2009-31, 2009-39 I.R.B. 395, provides guidance with respect to annual paid time off contributions. (2009 C. L.).
Rev. Rul. 2009-32, 2009-39 I.R.B. 398, provide…
Notice 2012-76 — This notice contains the 2012 Cumulative List of Changes in Plan Qualification Requirements (2012 Cumulative List) described in section 4 of Rev. Proc. 2007-44… IRCNoticesDec 27, 2012related by meaning
lective contributions. (2008 C. L.)
Notice 2007-7, 2007-1 C.B. 395, provides guidance regarding § 411(a), as amended by § 904 of PPA ’06. (2008 C. L.) Rev. Rul. 2012-4, 2012-8 I.R.B. 386, describes whether a qualified defined benefit pension plan that accepts a direct rollover of an eligible rollover distribution from …
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…
Notice 2007-81 — Interest rate modifications; Pension Protection Act of 2006; targeted segments. As required by section 430(h)(2) of the Code, as added by the Pension Protectio… IRCNoticesOct 29, 2007related by meaning
…ision of insurance between members of a consolidated group. REG-105964-98 withdrawn.
EMPLOYEE PLANS
Notice 2007-81 Notice 2007-81
Interest rate modifications; Pension Protection Act of 2006; targeted segments. As required by section 430(h)(2) of the Code, as added by the Pension Protection Act of 2006, the corporate bo…
IRCCourt RulingsSep 29, 1992
…ate of anticipated experience under the plan.
On March 29, 1990, respondent timely mailed Stephan a notice of deficiency determining a deficiency in income tax and an addition to tax under section 6659A for the taxable year ending July 31, 1987.
Boren Steel Consultants, Inc. (Boren Steel)
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…
Notice 2007-86 — This notice provides additional transition relief, under section 409A of the Code, that was scheduled to expire on December 31, 2007. Generally, this notice ex… IRCNoticesNov 13, 2007related by meaning
is not permitted after December 31, 2007. Notice 2007-78 modified. Section 3 of Notice 2006-79 modified and superseded.
Notice 2007-88 Notice 2007-88 This notice requests public comment on a proposal to change the process by which taxpayers obtain the consent of the Commissioner of Internal Revenue to change a method …
Notice 2008-113 — This notice provides taxpayers the ability to correct certain operational failures to comply with section 409A of the Code, or to limit the amount of additiona… IRCNoticesModified Dec 22, 2008related by meaning
ment entitled “§ 409A Relief under § [INSERT APPROPRIATE SECTION] of Notice 2008-113” setting out the information required by § IX.B.2 of this notice. A service provider who is relying on the relief provided in § V, § VI, or § VII of this notice with respect to a failure to comply with § 409A must attach to the service…
IRCCourt RulingsMay 3, 1995
… deduction for the balance in the amount of $1,025,021 ($1,705,633 - $680,612) for 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 expense…