Search the Pension Law Library

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. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
3. 82 T.C. 869; 82 T.C. No. 67 — Winger's Dep't Store, Inc. v. Commissioner
   IRCCourt RulingsJun 4, 1984
   On or about June 8, 1979, petitioner issued a check in the amount of $87,941.05 to the pension plan as its employer pension contribution for the 1978 year. The fate of this contribution differed slightly from that of the prior two contributions. The check was deposited on or about June 11, 1979, in the pension plan’s c…
4. 92 T.C. 1173; 92 T.C. No. 77 — Martin Fireproofing Profit-Sharing Plan & Trust v. Commissioner
   IRCCourt RulingsMay 31, 1989
   …wing deficiencies and additions to tax against petitioner: Year Deficiency Sec. 6651(a)(1) addition 1979 $10,465.83 $2,616.46 1980 21,265.76 5,316.44 1981 19,433.96 4,858.49 1982 3,841.48 960.37 1983 44,469.37 11,117.34 Respondent has conceded the additions. Thus, the instant case presents the following remaining issue…
5. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
   IRCCourt RulingsSep 30, 1985
   …red the possibility of establishing his own office in the Lapeer County area on or about January 1, 1979. Petitioner terminated his employment agreement with the clinic on June 30,1979, in anticipation of establishing his own office in the area. However, pursuant to paragraph 14 of petitioner’s employment agreement, pe…
6. 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
   or documents to which § 6104 (document open to public inspection) applies, as described in section 10.03. Taxpayer may protest deletions not made .05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
7. Treas. Reg. § 1.501(h)-3(e) — Lobbying or grass roots expenditures normally in excess of ceiling amount.
   IRCRegulationsJul 12, 2016
   …80,000) = $5,000}. For 1980, the tax is $10,000. For 1981, the tax is $1,250. (3) The taxable years 1979 through 1981 are all determination years under paragraph (c)(8) of this section. On its annual return for determination year 1979, the first year of its first election, X can demonstrate, under paragraph (b)(2) of t…
8. 85 T.C. 1031; 85 T.C. No. 60 — Anesthesia Service Medical Group, Inc. v. Commissioner
   IRCCourt RulingsDec 24, 1985★ strong match
   …ice Medical 1974 $4,155 Group, Inc. (ASMG) 1976 1,411 Docket No. 13936-83 1977 207,313 1978 264,619 1979 144,762 Anesthesia Service Medical 1977 332,602 Group, Inc. Employee Protective Trust (trust) 1978 1979 358,606 289,720 Docket No. 13935-83 By amended answer respondent determined increased deficiencies in tax of pe…
9. 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 (…
10. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000★ strong match
    …tment tax credit relating to the equipment, and they carried back and applied $894 of the credit to 1979, $10,331 of the credit to 1980, and $2,126 of the credit to 1981. Respondent audited Catamount and determined that Catamount was not entitled to an investment tax credit for 1982 because it had no basis in qualified…
11. 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…
12. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984
    was made (1978), and for the subsequent years as to which determinations have been made as to Cass (1979), Lueckel (1979), and Strong (1979 and 1980). We have had occasion to consider the effect of a taxpayer’s purpose and intent in making the excess contributions. We concluded that: "Willfulness is not an element in i…
13. Treas. Reg. § 1.412(c)(1)-2(f)(6) — Shortfall method.
    IRCRegulationsSep 9, 2016
    …est 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/B E/B E/B Base…
14. 84 FR 51471 — Application of the Employer Shared Responsibility Provisions and Certain Nondiscrimination Rules to Health Reimbursement Arrangements and Other Account-Based G…
    IRCProposed Rules (FR)Proposed Sep 30, 2019
    …aph (c)(3)(i)(B)( 2) of this section, are applicable for taxable years beginning after December 31, 1979 and for amounts reimbursed after December 31, 1979. In determining plan discrimination and the taxability of excess reimbursements made for a plan year beginning in 1979 and ending in 1980, a plan's eligibility and …
15. 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…
16. 92 T.C. 641; 92 T.C. No. 35 — Buzzetta Constr. Corp. v. Commissioner
    IRCCourt RulingsMar 27, 1989
    …ion Corp. 3/31/78 $4,178 Docket No. 3738-86 3/31/79 31,591 3/31/81 434 Anthony and Adamina Buzzetta 1979 36,760 Docket No. 3739-86 1980 27,831 1981 9,764 Richard and Marie Mar cant onio 1978 4,378 Docket No. 3740-86 1979 38,050 1980 29,409 1981 4,989 Vicenzo and Maria Buzzetta 1978 3,749 Docket No. 3741-86 1979 38,477 …
17. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980related by meaning
    ess., 1962-3 C.B. 261, 268-269. All of these rulings have been declared obsolete. Rev. Rul. 72-488, 1972-2 C.B. 649; Rev. Rul. 72-92, 1972-1 C.B. 408. Although petitioner does not directly argue that the regulation is void, it would, in effect, have us invalidate all of the regulations mentioned above. Because this Cou…
18. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983
    …ies); Moore v. Commissioner, 71 T.C. 533 (1979) (retail grocery store); Black v. Commissioner, T.C. Memo. 1983-245 (sales of developed real estate); Pilkington v. Commissioner, T.C. Memo. 1983-111 (operation of lounge); Smith v. Commissioner, T.C. Memo. 1983-93 (paint contracting business); Nelson v. Commissioner, T.C.…
19. 85 T.C. 168; 85 T.C. No. 10 — Eanes v. Commissioner
    IRCCourt RulingsJul 30, 1985
    …U.S. 940 (1971). We have followed this approach in many cases. E.g., Van Sant v. Commissioner, T.C. Memo. 1984-535; Craine v. Commissioner, T.C. Memo. 1984-513; Pizor v. Commissioner, T.C. Memo. 1979-487; Kacin v. Commissioner, T.C. Memo. 1979-410; Cooper v. Commissioner, T.C. Memo. 1979-256. See also Day v. Commission…
20. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…