IRCCourt RulingsAug 26, 1963related by meaning
422, 441.
Indeed', petitioner’s claim to deduction under sec. 162 (a),(1) Is based upon the assumption that these payments constitute “compensation.” The provisions incorporated in these regulations pertaining to sec. 404 of the 1954 Code were first promulgated In T.D. 6203, 1956-2 C.B. 256. Prior thereto, and shortly …
81 FR 7253 — Additional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014 IRCProposed Rules (FR)Proposed Feb 11, 2016
…or those benefits is referred to as a “make-whole agreement.” If the specific limitation of section 432(e)(9)(D)(vii) applies to a plan, then section 432(e)(9)(D)(vii)(I) requires that the suspension of benefits first be applied to the maximum extent permissible to benefits attributable to a participant's service with …
IRCCourt RulingsDec 19, 1989related by meaning
ps on questionable equitable considerations. The deficiency was correctly determined by the Commissioner.
Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of t…
81 FR 25540 — Suspension of Benefits Under the Multiemployer Pension Reform Act of 2014 IRCFinal Rules (FR)Apr 28, 2016
… reasonably accessible to those to whom notice must be furnished. Any notice provided under section 432(e)(9)(F)(i) will satisfy the requirement for notice of a significant reduction in benefits described in section 4980F. See section 432(e)(9)(F)(iv).
F. Approval or Rejection of Proposed Suspension
Section 432(e)(9)(G…
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
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for 1982 and that the related notice …
76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner IRCCourt RulingsMar 17, 1981related by meaning
implement the congressional mandate in some reasonable manner.’ ” (Citations omitted.) Commissioner v. Portland Cement Co. of Utah, 450 U.S. _ (1981). H. Rept. 2333,77th Cong., 1st Sess. (1942), 1942-2 C.B. 372,413; S. Rept. 1631, 77th Cong., 2d Sess. (1942), 1942-2 C.B. 541, 606-607. The specific changes made by Congr…
IRCCourt RulingsAug 22, 1994related by meaning
ribution to the fund and only to that extent will it constitute a deduction under section 162 in the year of transfer. * * * [Id., 1973-2 C.B. at 42.] In sum, these rulings referred to reserves for postretirement benefits as accumulations of assets and state that the deduction of contributions to such reserves is limit…
IRCCourt RulingsJan 26, 1984related by meaning
act represents reallocated forfeitures, the parties may be able to handle the matter under Rule 155, if that can be done without reopening the record. The Nov. 9,1977, letter stated the reasons for the proposed adverse determination as follows:
The final adverse determination letter, dated Mar. 28, 1979, stated in pert…
Rev. Proc. 2016-27 — This revenue procedure contains revised procedures for applications for a suspension of benefits under a multiemployer defined benefit pension plan that is in … IRCRevenue ProceduresMay 9, 2016
…tical and declining status to suspend benefits in certain situations. In particular, MPRA amended § 432(e)(9) of the Code and section 305(e)(9) of ERISA to permit the sponsor of a multiemployer defined benefit plan in critical and declining status to submit to the Secretary of the Treasury (Secretary) a proposal to sus…
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
tal wages. The regulations apply to all employers and others making supplemental wage payments to employees.
Announcement 2007-22 Announcement 2007-22 This document contains corrections to final regulations (T.D. 9263, 2006-25 I.R.B. 1063) relating to the deductions for income attributable to domestic production activi…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsMay 23, 1958related by meaning
ice of deficiency to each petitioner, determined that the payments to Carrie should not be eliminated through application of section 438 (b) (10) (C). In Arrow-Hart & Hegeman Electric Co., 7 T. C. 1350, this Court held that gratuity payments made by a corporation to widows of its deceased employees constituted a class …
IRCPrivate Letter RulingsMar 10, 2006related by meaning
ration of the taxing statutes. If a ruling is
revoked or modified, the revocation or modification applies to all open years under the
TAM-134113-05
15 statutes, unless the Commissioner or his delegate exercises the discretionary authority
under § 7805(b) to limit the retroactive effect of the revocation or modification…
IRCCourt RulingsSep 13, 1990related by meaning
of the maximum marital deduction formula clause nor does it eliminate the problem that Congress was addressing through enactment of section 403(e)(3). The majority and concurring opinions attempt to apply a literal approach by finding that the provision immediately after the maximum marital deduction formula clause rem…
IRCCourt RulingsJan 28, 2014related by meaning
vant facts." Lawinger v. Commissioner, 103 T.C. 428, 440 n.8 (1994).
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[*24] Substantial authority exists only when the weight of the authorities supporting the treatment of the tax item is substantial in relation to the weight of
the authorities supporting contrary treatment. Sec. 1.6662-4(d)(3)(i), Income Tax
Re…
IRCCourt RulingsDec 9, 1971related by meaning
n will be entered under Rule 50.
Drennen, /., dissents.
All statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. In addition to the $7.4 million per year, $1.2 million was to be contributed by the employers over a 3-year period to pay benefits which had vested under the 196.1 agree…
IRCCourt RulingsJul 24, 1984related by meaning
rectly involved in such ruling. * * *”
See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …
81 FR 27011 — Additional Limitation on Suspension of Benefits Applicable to Certain Pension Plans Under the Multiemployer Pension Reform Act of 2014 IRCFinal Rules (FR)May 5, 2016
…mployer assumes liability for those benefits is referred to as a “make-whole agreement.” If section 432(e)(9)(D)(vii) applies to a plan then, under section 432(e)(9)(D)(vii)(I), the suspension of benefits must first be applied to the maximum extent permissible to benefits attributable to a participant's service with an…
Notice 2017-49 — This notice provides relief in connection with certain employee benefit plans because of damage caused by Hurricanes Harvey and Irma. The relief provided by th… IRCNoticesOct 2, 2017
…ined Benefit Plans. For any multiemployer plan that is an Affected Plan, if the date described in § 432(b)(3)(A) of the Code and section 305(b)(3)(A) of ERISA by which the plan actuary must make any certification required under § 432(b)(3)(A) falls within the period beginning on the Initial Relief Date and ending on Ja…
IRCCourt RulingsMay 20, 1976related by meaning
tioners agreed to such adjustments and also to imposition of the negligence penalty (sec. 6653(a)) and paid the deficiency in tax and penalty.
OPINION Section 404(a) of the Code provides that if contributions are paid by an employer to or under a pension plan, such contributions “shall not be deductible under section 1…