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
…
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 …
IRCRegulationsSep 9, 2016
… through 1989 is as follows: Year ending December 31 Hours of service completed 1977 1,000 1978 800 1979 1,000 1980 400 1981 1,000 1982 0 1983 400 1984 1,000 1985 0 1986 0 1987 500 1988 200 1989 1,000 Employee A's status as a participant during this period is determined as follows: 1978: Employee A was a plan participa…
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
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…
IRCCourt RulingsOct 9, 1990★ strong match
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…
ERISARegulationsJan 1, 2017
…ake effect on the first day of the calendar year in which the purchase is concluded. On February 1, 1979, the negotiations conclude with Company A's purchase of Company B. The plan therefore becomes effective on February 1, 1979, retroactive to January 1, 1979. The summary plan description must be filed and disclosed n…
IRCCourt RulingsJul 26, 1989
…’ tax liabilities for 1977 and 1978, decided adversely to petitioners in Gord v. Commissioner, T.C. Memo. 1984-517. On June 19, 1986, the Court of Appeals affirmed our decision sub nom. Dillon v. United States, 792 F.2d 849 (9th Cir. 1986).
The parties also stipulated:
IRCCourt RulingsMay 15, 1978related by meaning
…ards provisions of ERISA. 29 Fed. Reg. 56462 (1976).
Ets-Hokin & Galvan, Inc. v. Commissioner, T.C. Memo. 1962-136.
The term “period of severance” is defined under sec. 2530.200b-9(a)(3)(v) as follows:
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 RulingsMar 13, 2001
…), affd. without published opinion 578 F.2d 1383 (8th
042 Cir. 1978); Bartley v. Commissioner, T.C.·Memo. 1998-322; Ruben
v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner,
T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696;
Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v.
Commissione…
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.…
IRCCourt RulingsMay 8, 2017
… expenses.
Funeral expenses are clearly personal or family expenses. See Beck v.
Commissioner, T.C. Memo. 2001-270, 2001 Tax Ct. Memo LEXIS 309, at *43
(holding that income tax deduction claimed for wife's funeral expenses was a
nondeductible personal expense); Carr v. Commissioner, T.C. Memo. 1979-400,
1979 Tax Ct. Me…
IRCCourt RulingsDec 19, 1995
…fer Refund does not constitute a qualified total
distribution. See Wittstadt v. Commissioner
, T.C. Memo. 1995492; Humberson v. Commissioner
, T.C. Memo. 1995-470; Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 ; Adler v. Commissioner
, T.C.
Memo. 1995-148; Dorsey v. Commissioner
, T.C. Memo. 1995-97; Brown
v. Commissi…
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…
IRCCourt RulingsFeb 10, 1997
…ontributions for deduction purposes.
* * * Corporation M is entitled to claim a deduction for
such [1979] contribution to the extent the deduction does
not
exceed the maximum deductible contribution for 1978.
[Priv. Ltr. Rul. 7945115, (Aug. 8, 1979); emphasis added.]
[2.] You state that Corporation M makes contribution…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
… and Mr. Robert MacDonald (Mr. MacDonald) incorporated
BI. From the time of its incorporation until 1979, Mr. Schoenecker and Mr. MacDonald each owned 50 percent of the stock
of BI.
In 1960 Mr. MacDonald had a driving accident and became a
paraplegic. He returned to work for BI on a part-time basis in
1963, and in 1979…
T.D. 9767 — Final regulations providing guidance under section 432(e)(9)(D)(vii) on an additional limitation on a benefit suspension with respect to certain multiemployer … IRCTreasury DecisionsMay 23, 2016related by meaning
ple, Deputy Commissioner for Services and Enforcement.
Approved: April 29, 2016.
Mark J. Mazur, Assistant Secretary of the Treasury (Tax Policy).
Note (Filed by the Office of the Federal Register on May 3, 2016, 4:15 p.m., and published in the issue of the Federal Register for May 5, 2016, 81 F.R. 27011)
[1] Section 20…
IRCCourt RulingsJun 10, 1996
…n or other physicians in the practice. He practiced as a
sole proprietor from 1975 until October 1, 1979. From sometime
in 1978 through October 1, 1979, the proprietorship employed
Gerald Walman (Walman) as an associate physician. On October 1,
1979, Pallin and Walman incorporated Lear Eye Clinic, Ltd.
2
(Lear). Pallin…
IRCCourt RulingsJan 27, 1998related by meaning
began on the date that the
prohibited transaction occurred, May 31, 1988, and ended on the
-14-
8
Petitioner contends that the second-tier tax of sec. 4975(b) is not applicable because of ERISA sec. 502(i), 29 U.S.C.
1132(i) (1988). ERISA sec. 502(i) provides the following:
In the case of a transaction prohibited by se…