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63 documents · 0.27sAllIRCERISAPBGCJoint Board
  1. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989★ strong match
    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…
  2. 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 …
  3. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    …itioner Robert C. Slaton was not a participant during the fiscal years of the plan ending Sept. 30, 1980, and Sept. 30, 1981. See Form 5500-C (1979). Sea 301.6058-(a)(4), Proced. & Admin. Regs., provides that the information return of a plan required by sec. 6058(a) shall be filed at the time required by the prescribed…
  4. Treas. Reg. § 1.411(b)-1(b)(2)(ii)(B) — Accrued benefit requirements.
    IRCRegulationsSep 9, 2016
    …ipant in the plan year is disregarded. Thus, for example, if for its plan year beginning January 1, 1980, a defined benefit plan provides an accrued benefit in plan year 1980 of 2 percent of a participant's average compensation for his highest 3 years of compensation for each year of service and provides that in plan y…
  5. 77 T.C. 881; 77 T.C. No. 62 — Achiro v. Commissioner
    IRCCourt RulingsOct 19, 1981
    …d and operated as such under the general business corporation statute of its State. For example, in 1980, Congress added to the Code present sec. 414(m) which is designed to aggregate the employees of an "affiliated service group” for purposes of certain pension and profit-sharing provisions. Sec. 414(m) does not prohi…
  6. ERISA § 4402(e) (29 U.S.C. § 1461) — Effective date; special rules
    PBGCCode / StatuteJan 6, 2017
    …), and (4), the amendments to this chapter made by the Multiemployer Pension Plan Amendments Act of 1980 shall take effect on September 26, 1980. (e)(2) (2) (e)(2)(A) (A) Except as provided in this paragraph, part 1 of subtitle E, relating to withdrawal liability, takes effect on September 26, 1980. (e)(2)(B) (B) For p…
  7. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    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…
  8. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    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.…
  9. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998
    … 430, 435 (1980); Keeton v. Commissioner , 74 T.C. 377, 381-382 (1980); Snow v. Commissioner , T.C. Memo. 1996-457. Th e taxpayer bears the burden of proving that the notice of deficiency was not sent to the taxpayer's last known address. Y usko v. C ommissioner , s upra at 808. "Taxpayers are required to send a clear …
  10. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    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…
  11. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …ctive dividend. Tennessee Sec. Inc. v. Commissioner , 674 F.2d 570, 573 (6th Cir. 1982), affg. T.C. Memo. 1978-434; Gardner v. Commissioner , 613 F.2d 160 (6th Cir. 1980), affg. T.C. Memo. 1976-349; Wortham Mach. Co. v. United States , 521 F.2d 160, 164 (10th Cir. 1975); Noble v. Commissioner , 368 F.2d at 442; Sachs v…
  12. T.C. Memo. 2016-29 — Mark Vandenbosch & Julie Vandenbosch v. Commissioner
    IRCCourt RulingsFeb 24, 2016
    …r. 1953), aff'g in part, rev'g in part 11 T.C.M. (CCH) 274 (1952), and Shaara v. Commissioner, T.C. Memo. 1980-247. Both Lashells' Estate and Shaara involved similar facts.¹7 The taxpayers received payments, portions of which they were required to pay over as kickbacks.¹8 Although the kickback agreements were unenforce…
  13. I.R.C. § 414(f)(4) — Definitions and special rules
    IRCCode / StatuteJan 6, 2025
    …ar which began before the date of the enactment of the Multiemployer Pension Plan Amendments Act of 1980, the term "multiemployer plan" means a plan described in this subsection as in effect immediately before that date. (f)(5) (5) Special election Within one year after the date of the enactment of the Multiemployer Pe…
  14. Treas. Reg. § 1.411(a)-6(d) — Year of service; hours of service; breaks in service.
    IRCRegulationsSep 9, 2016
    …89 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 participant on Janua…
  15. 88 T.C. 1474; 88 T.C. No. 83 — Leib v. Commissioner
    IRCCourt RulingsJun 16, 1987
    … of the time of trial, approximately 15 individuals had vested amounts in the trust. By the fall of 1980, petitioner had accumulated a block of stock in Cunningham Drug Stores, Inc. (Cunningham), a retail drug store chain whose stock was traded on the New York Stock Exchange. On November 18, 1980, the Detroit Free Pres…
  16. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  17. 76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner
    IRCCourt RulingsMar 17, 1981
    … for the same rules governing ESOPs with respect to cash and stock distributions. S. Rept. 96-1036 (1980), 1981-6 I.R.B. 41; H. Rept. 96-1278 (1980), 1981-6 I.R.B. 28. In sec. 141, Revenue Act of 1978, Pub. L. 95-600, 92 Stat. 2763, Congress enacted sec. 409A(h) which permitted distribution of property other than emplo…
  18. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984
    …* *” 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 interpreted as allowing some part …
  19. ERISA § 4217(a) (29 U.S.C. § 1397) — Application of part in case of certain pre-1980 withdrawals; adjustment of covered plan
    PBGCCode / StatuteJan 6, 2017
    …le to an employer for a partial or complete withdrawal from a plan which occurs after September 25, 1980, and for the purpose of determining whether there has been a partial withdrawal after such date, the amount of contributions, and the number of contribution base units, of such employer properly allocable— shall not…
  20. 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…