IRCCourt RulingsAug 13, 1990★ strong match
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 RulingsJan 3, 2017
…tory, creating no
legally enforceable rights for taxpayers. See, e.g., Greene v. Commissioner, T.C.
Memo. 1992-202, 1992 Tax Ct. Memo LEXIS 239; Tucker v. Commissioner, T.C.
Memo. 1983-210, 1983 Tax Ct. Memo LEXIS 578; Chapman v. Commissioner,
T.C. Memo. 1982-68, 1982 Tax Ct. Memo LEXIS 675; see also Marks v.
Commissio…
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsJan 19, 2001
…olders.
1
Walter and Barbara were married in 1956. They both worked
for petitioner. From 1967 until 1983 or 1984, Barbara
essentially ran the office; she worked full time for petitioner
as office manager, bookkeeper, and corporate secretary. Barbara
had a good rapport with customers; in general customers preferred
deal…
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…
IRCCourt RulingsOct 3, 1995related by meaning
…e year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10066-93. Filed October 3, 1995.
Harold L. Humberson, pro se.
Alan R. Pere…
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…
IRCRegulationsMay 18, 2016
…ample. The provisions of this paragraph may be illustrated by the following example: Example.In the 1983 taxable year, Employer A makes a withdrawal liability payment of $700,000 to multiemployer Plan X to which Employer A and Employer B are required to contribute. Employer A's allocable share of the deduction allowabl…
IRCCourt RulingsJun 11, 1996related by meaning
…in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20303-94. Filed June 11, 1996.
Janet I. McCurdy
, for petitioners.
Alan…
ERISARegulationsJan 1, 2017
…ring one-year breaks in service for purposes of eligibility to participate). Thus, as of January 1, 1983, the employee is credited with six years of service for purposes of eligibility to participate and is credited with one year of participation. In accordance with section 203(b)(1)(A) of the Act and section 411(a)(4)…
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 …
89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary ERISAFinal Rules (FR)Apr 25, 2024
…PTE 77-9, 41 FR 56760, 56762 (Dec. 29, 1976) and U.S. Department of Labor Adv. Op. 83-60A (Nov. 21, 1983), available at
https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/advisory-opinions/1983-60a).
Back to Citation
210.
Regulation Best Interest release, 84 FR 33318, 33319 (July 12, 20…
IRCCourt RulingsApr 11, 2012related by meaning
…red by the Joint
Committee on Taxation (the Blue Book); privatd letter rulings and
technical advice memoranda issued after October 31, 1976; actions on
decisions and general counsel memoranda issued after March 12,
1981 (as well as general counsel memoranda published in pre-1955
volumes of the Cumulative Bulletin); Int…
IRCCourt RulingsMar 5, 1987related by meaning
amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
IRCCourt RulingsMay 9, 1988★ strong match
…plans did not arise in the context of a determination as to whether the plan was qualified.
(G) The 1983 Application Thereafter, the trustees of the Teamsters Fund, also claiming to act as successor trustees of the Brewery Workers Fund, filed another request for a determination, dated September 30, 1983, with the Distr…
IRCCourt RulingsJul 24, 1989
…tion letters were sent by certified mail to petitioner at the Lake Charles address on September 23, 1983. Each letter contained the paragraph: If you do not agree, you can appeal within 30 days from the date of this letter through this Key District Office. To file your appeal, please follow the instructions in the encl…
REG-124988-05 — Proposed regulations under section 412 of the Code provide guidance regarding mortality tables to be used in determining the current liability of a qualified d… IRCProposed Rules (FR)Proposed Dec 19, 2005
…(other than disabled participants). The existing mortality table for determining current liability (1983 GAM) was compared to independent studies of mortality of individuals covered by pension plans, after reflecting projected trends for mortality improvement through 2007. The comparison indicates that the 1983 GAM is …
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 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 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…