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62 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    … 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. 78 T.C. 930; 78 T.C. No. 66 — Hauser v. Comm'r
    IRCCourt RulingsJun 9, 1982
    …b) analysis be applied as though the 1978 rules had been adopted and had taken effect on October 1, 1976. Thus, because section 401(b) states that the plan shall be considered to have been qualified under the 1978 rules from October 1, 1976, respondent argues that petitioner was an active participant in a qualified pla…
  3. 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,…
  4. 78 T.C. 86; 78 T.C. No. 6 — Horvath v. Commissioner
    IRCCourt RulingsJan 20, 1982
    …ert and Virginia R. Horvath, husband and wife, filed a joint Federal income tax return for the year 1976 with the Internal Revenue Service Center at Fresno, Calif. Petitioners resided in Alamo, Calif., at the time their petition herein was filed. Petitioner Virginia R. Horvath (Mrs. Horvath) was employed by U.S. Steel …
  5. 77 T.C. 477 — Chapman v. Commissioner
    IRCCourt RulingsAug 24, 1981
    …ts in the plan received benefits keyed to their years of credited service. With respect to the year 1976, petitioner accrued benefits under the plan for the period beginning January 1, 1976, and ending August 31, 1976. He was credited with a total of 1,301 hours for this period. Section 2.11.5 of the Blue Cross/Blue Sh…
  6. 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…
  7. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    ciency, id. , petitioner cites Chrysler Corp. v. Brown , 441 U.S. 281 (1979), for the proposition that respondent’s reopening procedures in Rev. Proc. 94-68, 1994-2 C.B. 803, should have “the force and effect of law”. Chrysler Corp. v. Brown , 441 U.S. at 302 (quoting Morton v. Ruiz , 415 U.S. 199, 232, 235, 236 (1974)…
  8. 70 T.C. 214; 1 Employee Benefits Cas. (BNA) 1835 — Automated Packaging Systems, Inc. v. Commissioner
    IRCCourt RulingsMay 15, 1978★ strong match
    …ards provisions of ERISA. 29 Fed. Reg. 56462 (1976). Ets-Hokin & Galvan, Inc. v. Commissioner, T.C. Memo. 1962-136. The term “period of severance” is defined under sec. 2530.200b-9(a)(3)(v) as follows:
  9. IRCRegulationsSep 9, 2016
    …tation of Earliest Base Unit Estimation Date Example Plan year (calendar year basis) 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 Plan A V V V V Contract 1 E/B E/B E/B E/B Base unit estimation date 1 1973 1973 1973 1976 1976 1979 1979 1979 1979 Plan B V V V V Contract 2 2 2 2 B* E/B E/B* Contract 3 E/B E…
  10. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    …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 (…
  11. 74 T.C. 1057 — Johnson v. Commissioner
    IRCCourt RulingsAug 12, 1980
    …excess contribution for 1975. Orzechowski v. Commissioner, supra; Guest v. Commissioner, supra. For 1976, the calculation is a bit more complicated, but the result is the same — $1,500 of excess contribution. The introductory language of section 4973(b) defines “excess contribution” as the sum of the amount determined …
  12. 76 T.C. 1156 — Sullivan v. Commissioner
    IRCCourt RulingsJun 30, 1981
    OPINION Nims, Judge-. Respondent determined a deficiency in petitioners’ income tax for 1976 in the amount of $4,705. The issue for decision is whether one-half of the lump-sum payments petitioners received during 1976 from qualified pension and profit-sharing plans, which amount was treated as long-term capital gain p…
  13. 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))…
  14. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    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…
  15. Treas. Reg. § 1.414(f)-1(b)(2)(ii) — Definition of multiemployer plan.
    IRCRegulationsSep 9, 2016
    …a)(4) and (b)(2)(i) of this section are illustrated by the following example: Example.On January 1, 1976, employer W became a member of the noncontributory XYZ pension plan which uses the calendar year as the plan year. W did not maintain any plan prior to that date. The plan provided for benefits of $4 per month per y…
  16. IRCCourt RulingsAug 3, 1979
    …ons under the regular pension plan allocable to the employee. The Joint Conference Committee on the 1976 Act dropped both the House and the Senate provision but provided for a study of the problem. S. Rept. 94-1236 (Conf. Rept.), pp. 242-243, 512 (1976), 1976-3 C.B. (Vol. 3) 807,916. See General Explanation of the Tax …
  17. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988
    …of section 411(d)(3) of the Internal Revenue Code and the regulations thereunder between January 1, 1976 and September 30, 1976, prior to the effective date of the merger agreement of the Brewery Fund into the New York State Teamsters Conference Pension and Retirement Fund. Based on the facts submitted, we have determi…
  18. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984
    5 None 1976 The extent of employee turnover between 1962 and 1974 was beyond the company’s control and could not have been anticipated by the company. The trust continued in effect without amendment from 1962 until July of 1976, when the company determined that it should be terminated. Upon the trust’s termination in 1…
  19. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981
    …courts. Joint Comm, on Taxation, 94th Cong., 2d Sess., General Explanation of the Tax Reform Act of 1976, 1976-3 C.B. (Vol. 2) 416. See also H. Rept. 94-658 (1975), 1976-3 C.B. (Vol. 2) 978; S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 626-627. Proceeding with this declaratory judgment action would not only be duplicat…
  20. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981
    filed their petition in this case. They filed their joint Federal income tax returns for 1975 and 1976 with the Internal Revenue Service, Austin, Tex. During 1975 and 1976, Mr. Cobb was an attorney-at-law, employed by the law firm of Cobb, Thurmond & Bain, Inc. The offices of such firm were located in the Frost Nationa…