Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to T.C. Memo. 1995-441 (not yet in the library — opens the official source)
63 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 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 …
  2. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1 Unless otherwise indicated, all section references are to (continued...) T.C. Memo. 1999-199 UNITED STATES TAX COURT DON LAVERNE CLARKE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 151-97. Filed June 18, 1999. Don Laverne Clarke, pro se. Anthony Hoefer , for respondent. MEMORANDUM FINDINGS …
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    … and June 30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M. (CCH) 1707 (a case involving tax years 1979, 1980, and 1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d 825 (5th Cir. 1996) In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
  4. T.C. Memo. 2003-12 — Richard J. Meyer, III v. Commissioner
    IRCCourt RulingsJan 13, 2003
    …r) is entitled to alimony deductions in amounts greater than those conceded by respondent for 1994, 1995, and 1996; (2) whether Mr. Meyer is entitled to dependency exemptions for 1994, 1995, and 1996 for his only child; (3) whether Mr. Meyer is entitled to a child care credit for 1994, 1995, and 1996; (4) whether Mr. M…
  5. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    e not binding on any government agency other than the United States Department of Labor." On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise tax deficiencies pursuant to section 4975(a) and (b), as well as additions to tax. Respondent determine…
  6. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    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 .…
  7. 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 …
  8. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    … • warnings that he was in danger of being penalized. For example, in Mathews v. Commissioner, T.C. Memo. 2005-84, we told petitioner: "Even though the filing of the petition resulted in respondent's concession of the sec. 72(t) additional tax,
  9. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  10. Treas. Reg. § 1.414(r)-5(f)(5) — Qualified separate line of business—administrative scrutiny requirement—safe harbors.
    IRCRegulationsSep 9, 2016
    …ce conditions under any plan of the employer. All other employees of Line 1 and Line 2 on March 31, 1995 are nonexcludable employees for purposes of the average benefit percentage test during the 1995 testing period.(iii) In order for Line 1 to satisfy the requirements of this paragraph (f) for 1995, the actual benefit…
  11. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    Parker, Judge: By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows: _Additions to tax_ Sec. Sec. Sec. TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1/31/86 $64,117 $3,206.85 50 percent $16,029.25 of the interest …
  12. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996★ strong match
    …he Retirement System and the Pension System as a single pension plan. Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissioner , T.C. Memo. 1995-93; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , - 13 - T.C. Memo. 1994-633; see Wheeler v. Commissioner , T.C. Memo. 1993-561; see also S…
  13. 117 T.C. No. 19 — The Board of Trustees of the Sheet Metal Workers' National Pension Fund, In Its Capacity As Plan Administrator v. Commissioner
    IRCCourt RulingsDec 4, 2001
    to a technical advice memorandum dated November 9, 1994 (regarding provisions not at issue in this case), as well as to comply with amendments to the Code. The application contained the amended and restated plan that petitioner adopted on December 22, 1994. It also contained a copy of a proposed amendment to article 8…
  14. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
  15. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    regardless of whether such events predate or postdate our announcement of the rule. [ Harper v. Virginia Dept. of Taxation , 509 U.S. 86, 97 (1993).] On the basis of the Supreme Court's opinion in Commissioner v. Keystone Consol. Indus., Inc. , 508 U.S. 152 (1993), we sustain respondent's determination that petitioner…
  16. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000
    …er is liable for additions to tax under section 6654 for the failure to pay estimated taxes for the 1995 and 1996 taxable years; (5) whether petitioner is liable for accuracy-related penalties under section 6662(a) for the underpayment of taxes for the 1994 and 1995 taxable years; and (6) whether a penalty should be aw…
  17. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997
    …r similar NOA agreements are independent contractors or employees. Mosteirin v. Commissioner , T.C. Memo. 1995-367; Smithwick v. Commissioner , T.C. Memo. 1993-582, affd. per curiam sub nom. Butts v. Commissioner , 49 F.3d 713 (11th Cir. 1995); Butts v. Commissioner , T.C. Memo. 1993-478, affd. per curiam 49 F.3d 713 (…
  18. T.C. Memo. 1996-354 — Brent Allan Pulliam v. Commissioner
    IRCCourt RulingsAug 1, 1996related by meaning
    event the diversion of retirement savings for nonretirement purposes and to recapture a measure of the tax benefits provided by the deferral of income tax through retirement plans. At the same time, Congress recognized that it was appropriate to provide, under limited circumstances, an exemption from the tax for certai…
  19. T.C. Summary Opinion 2001-8 — Peter Spuler, Jr. v. Commissioner
    IRCCourt RulingsFeb 2, 2001
    …Co Inc, SEP-IRA DTD 11/20/93". Contributions were made to the account in the amounts of $27,500 for 1995 and $30,000 for 1996. Petitioner also paid $3,079 and $4,570 for self-employed health insurance for 1995 and 1996. Petitioner’s father, Peter J. Spuler, Sr. (Mr. Spuler), died in 1995. During that year petitioner re…
  20. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007related by meaning
    … related to their investment in the partnerships; FPAAs were - 25 - 13 Bales v. Commissioner , T.C. Memo. 1989-568, involved deficiencies determined against various investors in several Hoyt partnerships. This Court found in favor of the investors on several issues, stating that “the transaction in issue should be resp…