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 RulingsFeb 9, 2023related by meaning
arties at the original contract date.” Notice 88-123,
1988- 2 C.B. at 477.
145
JJ. T
he 1988 amendment to section 7805 regarding temporary
regulations In 1988, Congress added section 7805(e), which provided:
SEC. 7805 (e). Temporary Regulations. --
(1) Issuance. --Any temporary regulation
issued by the Secretary shall …
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…
IRCCourt RulingsSep 25, 1996
…ks stamped with the signature of Andrew Bryen (Andrew
Bryen physically signed three W & A checks in 1987).
One of the employees paid with W & A checks was Loretta
Wilcox, a secretary with Machise. She had been hired by Bucci in
September 1980, after she had filled out a formal employment
- 86 -
application. She could n…
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
ed do not apply to requests for any documents to the extent § 6104 applies.
Statement identifying information to be deleted from public inspection
.04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
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. 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…
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…
IRCCourt RulingsJul 15, 1997★ strong match
x
6651(a)(1)
6653(a)(1)(A)
6653(a)(1)(B)
6661(a)
1987 $7,348-367
1
-
1988 29,345 2,935 1,467-7,336
1
50 percent of the interest due on the deficiency. Unless otherwise indicated, all section and Code references
are to the Internal Revenue Code as in effect for the years in
issue, and all Rule references are to the Tax …
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
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…
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 (…
IRCCourt RulingsMar 5, 2018
…d only for clear error on appeal), aff'g in part, rev'g in part 89 T.C. 1229
(1987), and aff'g T.C. Memo. 1987-625, T.C. Memo. 1987-626, and T.C. Memo.
1987-628; but see Sacks v. Commissioner, 69 F.3d 982, 986 (9th Cir. 1995)
(determination that transaction a sham is reviewed for clear error on underlying
facts and de …
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…
IRCCourt RulingsSep 3, 1998★ strong match
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
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…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCPrivate Letter RulingsMar 3, 2000related by meaning
…C:EBEO:4
TL-N-4712-99
UILC: 419.00-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR
FROM: Assistant Chief Counsel (Employee Benefits and Exempt
Organizations) CC: EBEO
SUBJECT:
This Field Service Advice is in res ponse to your memorandum dated October 5,
1999. Field Service Advice is not …
IRCCourt RulingsFeb 12, 2003related by meaning
…ovided calculations to establish that the plan
was qualified as of the taxable year ending June 30, 1987. In
their calculations, petitioners have ignored findings from the
declaratory judgment; i.e., $30,000 treated as an employee
- 11 -
contribution and $9,000 treated as an employer contribution for
taxable year ended…