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21. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    …arifying” the "existing” law by rejecting respondent’s position regarding the applicability of sec. 403 to public school employees. Neither party has advanced any argument herein based upon the legislative history of sec. 403(b) and of sec. 2039(c). Nor was this legislative history considered in Estate of Johnson v. Co…
22. 102 T.C. 695; 102 T.C. No. 31 — Fazi v. Commissioner
    IRCCourt RulingsMay 19, 1994
    …ollowing dissolution of the corporation on December 31, 1986, plan 1 was terminated on November 10, 1987, and the assets of the trust associated with plan 1 were distributed to plan participants, including petitioners. Within 60 days, petitioners rolled over their distributions, totaling $1,128,785.16 ($1,110,300.24 fo…
23. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    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…
24. 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…
25. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    oner , T .C . Memo . 2004-125 . - 6 - Petitioner has not argued, and she has failed to demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right . Consequently, we must uphold TRHCA section 408 if it bears a rational relationship to a legitimate govern…
26. 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…
27. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
28. 109 T.C. No. 21 — Lakewood Associates; Robert G. Moore, Tax Matters Partner v. Commissioner
    IRCCourt RulingsDec 29, 1997
    … that causes discharge of dredge or fill material on wetlands. 4 See 33 U.S.C. sec. 1344 (1994). In 1987, the Corps published a manual defining protected wetlands, Federal Manual for Identifying and Delineating Jurisdictional Wetlands (1987 Manual). The Norfolk Division of the Corps, which has local oversight of the Ch…
29. 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 …
30. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    …96, we lack jurisdiction to abate - 8 - interest herein. See Commissioner v. McCoy , 484 U.S. 3, 7 (1987); 508 Clinton Street Corp. v. Commissioner , 89 T.C. 352, 354 (1987). Decision will be entered for respondent with respect to the deficiency, including the additional tax under sec. 72(t), and decision will be enter…
31. 105 T.C. No. 29 — John U. & Sylvia Fazi v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …olved C in 1986 and distributed all of the assets in the plan 1 trust to employees, including P, in 1987. We held in Fazi v. Commissioner , 102 T.C. 695 (1994) (Fazi I), that plan 1 was not qualified and its related trust was not exempt during 1985, 1986, and 1987. We also held that, except for amounts conceded by R, P…
32. 99 T.C. 9; 99 T.C. No. 2 — Vinson & Elkins v. Commissioner
    IRCCourt RulingsJul 14, 1992
    …uarial Information (Forms 5500), with respect to each plan for the September 1, 1986, to August 31, 1987 (1986 plan year), and September 1, 1987, to August 31, 1988 (1987 plan year), plan years. He certified on the Forms 5500 that for each plan the assumptions used in the aggregate were reasonably related to the experi…
33. 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 …
34. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    , 1485 (2021) (“ [A]s this Court has long made plain, pleas of administrative inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105, 2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is clear, that is the…
35. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991
    J. Guilzon. Petitioners filed their Federal income tax return and an amended return for 1987 with the Internal Revenue Service Center, Austin, Texas. Petitioner was employed by the U.S. Army Corps of Engineers for over 30 years before retiring on January 3, 1987, at which time he was over the age of 55.2 He participat…
36. 101 T.C. 489; 101 T.C. No. 32 — Powell v. Commissioner
    IRCCourt RulingsNov 29, 1993related by meaning
    aws. As to the precedential value of Memorandum Opinions, see, e.g., Newman v. Commissioner, 68 T.C. 494, 502 n.4 (1977). [Id. at 67; emphasis added.] In light of our restrained articulation in Darby, and particularly its caveat as to a community property situation, we are satisfied that Darby does not compel a decisio…
37. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984related by meaning
    …to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining whether a partial termination has occurr…
38. T.C. Memo. 2011-58 — Erin N. Hellweg v. Commissioner
    IRCCourt RulingsMar 9, 2011related by meaning
    4 (1984); see United States v. Mead Corp., 533 U.S. 218 (2001). Although they may be entitled to deference under Skidmore v. Swift & Co., 323 U.S. 134 (1944), see United States v. Mead Corp., supra, we need not decide whether Notice 2004-8, supra, should be given Skidmore deference because the Transaction does not féll…
39. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
40. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    other grounds, and remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206; Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 - II. Administrative Costs The administrative costs at issue are costs that petitioner incurred from the . time respondent issued the notice of deficiency up to the …