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
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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
… 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…
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 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,…
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…
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…
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 RulingsJun 3, 1998related by meaning
been finalized. Moreover, even if the
proposed regulation were final, it would not, by its terms,
apply to the 1986 loans. See sec. 1.72(p)-1, Q&A-19, Proposed Income Tax Regs. 63 Fed. Reg. 42, 47 (Jan. 2,
1998) (regulation applies to "loans made on or after the
date that is three months after the date of publication o…
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003related by meaning
rders) applies for transfers, distributions, and payments made after December 31, 2001.
Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
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 RulingsAug 6, 1991★ strong match
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
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 RulingsMar 20, 1997★ strong match
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
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…
IRCCourt RulingsJul 15, 1997
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 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 RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
IRCCourt RulingsMay 19, 1994
…ollowing dissolution of the corporation on December 31, 1986, plan 1 was terminated on November 10, 1987, and the assets of the trust associated with plan 1 were distributed to plan participants, including petitioners. Within 60 days, petitioners rolled over their distributions, totaling $1,128,785.16 ($1,110,300.24 fo…
IRCCourt RulingsMar 31, 2015related by meaning
Commissioner's determination for abuse of discretion. E2, Sego v.
- 18 -
[*18] Commissioner, 114 T.C. at 610. The Appeals Office abuses its discretion when its exercise of discretion is arbitrary, capricious, or without sound basis in
fact or law. Murphy v. Commissioner, 125 T.C. 301, 308, 320 (2005), aff'd, 469
F.3d 2…