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1. 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…
2. 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
   of mandatory technical advice .04 Requests for §7805(b) relief are mandatory TAMs with respect to all exempt organizations and employee plans matters. Regarding exempt organizations matters, EO Examinations, EO Determinations and appeals offices are required to request a TAM on their exempt organization cases concernin…
3. 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…
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. 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…
6. 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…
7. 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,…
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. Treas. Reg. § 1.412(c)(1)-2(f)(6) — Shortfall method.
   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. 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 …
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. 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 (…
14. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    … sold insurance products as an employee of Fidelity Union Life Insurance Company (Fidelity). During 1976 and 1977, petitioner operated as a sole owner and paid for the costs of operating her business as an independent insurance salesperson with Fidelity. Petitioner reported her 1976 and 1977 earnings from the sale of F…
15. 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))…
16. 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…
17. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
18. 72 T.C. 768; 1 Employee Benefits Cas. (BNA) 1603 — Guest v. Commissioner
    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 …
19. 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…
20. 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…