Search the Pension Law Library

21. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …
22. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
23. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
24. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    lowing compensation, including salary, bonuses, and deferred amounts: Company 1972 197U J. C. Penney. $551,000 $154,000 Sears Roebuck. 478,000 344,000 May Department Stores. 304,000 310,000 Mercantile Stores. 286,000 263,000 Allied Stores. 275,000 275,000 F. W. Woolworth. 271,000 331,000 Federated Department Stores. 26…
25. 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 …
26. 66 T.C. 82 — Sarmir v. Commissioner
    IRCCourt RulingsApr 12, 1976
    …ective retirement benefit of $92.12 per month, or a single sum payment of $2,126.57. On October 17, 1972, petitioner executed the annuity benefit form on which he elected to receive a single lump-sum payment in the amount of $2,126.57. Pursuant to this election, on November 10, 1972, Bankers sent a check in that amount…
27. Treas. Reg. § 1.72-17(ii)(iv) — Special rules applicable to owner-employees.
    IRCRegulationsJul 26, 2016
    …cess of 10 percent in the partnership and continued to participate in the profit-sharing plan until 1972. During 1972, prior to the time he attained the age of 59 1/2 years and during a time when he was not disabled, B withdrew his entire interest in the profit-sharing plan. At that time his interest was $15,000, $9,60…
28. Treas. Reg. § 1.72-17A(ii)(2)(iv)(A) — Special rules applicable to employee annuities and distributions under deferred compensation plans to self-employed individuals and owner-employees.
    IRCRegulationsMar 14, 2019
    …,500 $900 $300 1975 7,500 2,500 4,000 1,300 1974 7,500 2,500 1,800 700 1973 2,500 2,500 1,200 1,200 1972 2,500 2,500 1,300 1,300 Totals 27,500 12,500 9,200 4,800 (2) The amount of the $54,000 distribution to which subdivision (i)(A) of this subparagraph applies is $20,000, computed as follows: X contributions on behalf…
29. 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…
30. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    …t. 2, 1974] Petitioner also refers to the plan in St. Joseph Bank & Trust Co. v. Commissioner, T.C. Memo. 1975-182. Respondent made no argument that in any event the adoption of a plan on Apr. 15, 1975, was untimely. However, sec. 401(b), I.R.C. 1954 (n. 15 supra), limits retroactive changes in profit-sharing plans to …
31. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
32. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
33. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    … years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-277 UNITED STATES TAX COURT MARGARET M. MERKER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26855-95. Filed June 18, 1997. Margaret M. Merker, pro se. Marjory A. Gilbert , for respon…
34. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995related by meaning
    …r discovery until the case was recalled for trial at a special session held 20 5 Petitioner filed a Memo to the Court on May 23, 1994, requesting that the Court order respondent to produce and turn over to petitioner documents relating to the examination of petitioners' returns. We do not recognize this Memo as a forma…
35. 95 T.C. 415; 95 T.C. No. 30 — Albertson's, Inc. v. Commissioner
    IRCCourt RulingsOct 9, 1990related by meaning
    o. v. Commissioner, 30 T.C. 10, 22-23 (1958), affd. 267 F.2d 853 (7th Cir. 1959); Times Publishing Co. v. Commissioner, 13 T.C. 329, 335 (1949), affd. per curiam 184 F.2d 376 (3d Cir. 1950). Section 23(p) was reenacted as section 404 in the 1954 Code in essentially the same form. Don E. Williams Co. v. Commissioner, 42…
36. 70 T.C. 1046 — Holland v. Commissioner
    IRCCourt RulingsSep 25, 1978
    …petitioner” alone will be to John C. Holland. Petitioners timely filed joint income tax returns for 1972 and 1973 with the Internal Revenue Service Center, Memphis, Tenn. During 1972 and 1973 petitioner operated an unincorporated maintenance contracting business. His business consisted principally of collecting and dis…
37. 70 T.C. 1001; 1 Employee Benefits Cas. (BNA) 1981 — Pulver Roofing Co. v. Commissioner
    IRCCourt RulingsSep 19, 1978
    …271 F.2d 865, 868 n. 1 (2d Cir. 1959). Nor are we convinced that the result should be different for 1972. During that year, four of the eight plan participants were members of the prohibited group and four were not members, out of a total of 51 employees. At the time the plan was adopted, there was a total of 76 employ…
38. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984
    …ufficient control over available work to insure that force levels will remain constant. In 1971 and 1972, petitioner experienced reductions in work force. The reductions in force were not due to a liquidation of petitioner or any of its divisions but simply to the inherent volatility of the consulting engineering busin…
39. 84 T.C. 13; 84 T.C. No. 2 — Hockaden & Associates, Inc. v. Commissioner
    IRCCourt RulingsJan 9, 1985related by meaning
    section 4975 as follows: (c) Effective Date and Savings Provisions.— (1)(A) The amendments made by this section shall take effect on January 1, 1975. (B) If, before the amendments made by this section take effect, an organization described in section 401(a) of the internal Revenue Code of 1954 is denied exemption unde…
40. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …