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 RulingsDec 11, 1997
…arying amounts of Harrah Bancshares stock.
In an attempt to repay the 1982 plan loan, on August 19,
1985, petitioner transferred to the Hickman corporation profitsharing plan 5,000 shares of Harrah Bancshares stock (Harrah
Bancshares profit-sharing plan stock) and certain real property
located in Oklahoma County, Oklah…
IRCCourt RulingsFeb 12, 2003related by meaning
…ource of many of
petitioners’ calculations; i.e., figures for taxable years ended
June 30, 1984 and 1985, is unclear, and such figures are not
reflected in the instant records. The declaratory judgment
clearly examined the years at issue. We do not question those
calculations. We therefore shall grant respondent’s moti…
IRCRegulationsJul 12, 2016
…plans to voluntarily revoke its expenditure test election effective beginning with its taxable year 1985. X must file its notice of voluntary revocation on Form 5768 after December 31, 1983, and before January 1, 1985. If X files a notice of voluntary revocation on December 31, 1984, the revocation is effective beginni…
IRCCourt RulingsSep 30, 1985related by meaning
nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
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 …
IRCCourt RulingsSep 29, 1992
Valley. King’s salary, on the accrual basis, from Citrus Valley for the years 1985 through 1988 was $67,400, $80,000, $87,200, and zero, respectively. In 1985, Citrus Valley adopted a defined benefit pension plan. King was the only participant in the plan during the years 1985 through 1988. On May 9, 1986, Citrus Valle…
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 …
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 RulingsMar 23, 1987
…tember 16, 1981. WSI adopted amendments to the plan on January 3, 1984, June 29, 1984, and July 23, 1985. WSI filed with respondent on March 14, 1984, a request for a determination that the plan, as amended, continued to qualify under section 401(a).
Respondent issued a proposed adverse determination letter with respec…
Ann. 2004-72 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba… IRCAnnouncementsOct 12, 2004
…s, Inc. (Nationwide Financial Services, Inc.) One Nationwide Plaza Columbus, OH 43216 September 25, 1985 160. Nationwide Credit Union One Nationwide Plaza Columbus, OH 43216 April 13, 1978
161. NBC Securities, Inc. 1927 First Avenue North Birmingham, AL 35203 July 16, 1996
162. Neuberger & Berman 522 Fifth Ave. New Yor…
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…
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 …
IRCCourt RulingsMar 20, 1997
…and Milo Chapman $25,000 plus 12 percent interest (collectively
referred to as corporate loans).
In 1985, Dura-Craft paid David Christie $10,000 on its
$50,000 corporate loan, and Springbrook paid Milo Chapman $10,000
on its $25,000 corporate loan. At that time, Dura-Craft reduced
its loan payable balance reflected in …
IRCCourt RulingsMay 13, 1999
ted on August 9, 1985, and its
principal business activity is real estate sales. It is the
employer and plan administrator with respect to the ESOP, a defined contribution plan. Petitioner established the ESOP and
the trust as of August 12, 1985, effective for plan years
beginning on and after August 12, 1985. The plan…
IRCCourt RulingsOct 17, 1995
beginning in 1985, which was more than 3
years prior to the date on which the property was sold.
Generally, sections 1001 and 61 require a taxpayer to recognize in the year of the sale gain realized on the sale of
property. Section 1034, however, allows a taxpayer, in certain
circumstances, to defer recognition of gain…
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 RulingsMay 19, 2011
…. 274(d); sec. 1.274-5T(a), (c) (1), Temporary Income Tax Regs., 50 Fed. Reg. 46006, 46016 (Nov. 6,
1985). To meet the adequate records requirements of section
274(d), a taxpayer must maintain an account book, a log, or other
documentary evidence which, in combination, is sufficient to
- 57 -
establish each element of …
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…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999
… which it approved
revisions to the FUH plan. These meetings included: (1) July
25, 1983, March 11, 1985, and October 28, 1985, at which the
committee approved the FUH plan; and (2) July 23, 1984, at which
the committee agreed to use $225,000 received from Travelers for
the first death under the plan to buy six or seve…