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…
T.D. 9319 — Final regulations contain amendments to the regulations under section 415 of the Code regarding limitation on benefits and contributions under qualified plans.… IRCTreasury DecisionsApr 30, 2007
Comprehensive regulations regarding section 415 were last issued in 1981. See T.D. 7748, 1981-1 C.B. 259, published in the Federal Register on January 7, 1981 (46 FR 1687). Since then, changes to section 415 have been made in the Economic Recovery Tax Act of 1981, Public Law 97-34 (95 Stat. 320) (ERTA), the Tax Equity …
IRCPrivate Letter RulingsNov 30, 2018
…contributions.
Revenue Ruling 2006-43, 2006-35 I.R.B. 329, amplifying and modifying Rev. Rul. 81-35
1981-5 I.R.B. 11, 1981-1 C.B. 255, Rev. Rul. 81-36 1981-5 I.R.B. 12, 1981-1 C.B. 255,
and Rev. Rul. 87-10 1987-5 I.R.B. 4, 1987-1 C.B. 136, des cribes the actions required
for a state or political subdivision of a state,…
IRCCourt RulingsFeb 14, 1996
… the computation to start on the same date the COLA's were started under the EAJA; i.e., October 1, 1981. Id.
at 23. Citing Lawrence v. Commissioner
, 27 T.C. 713 (1957),
revd. on other grounds 258 F.2d 562 (9th Cir. 1958), we stated
that we would continue to use 1981 as the correct year for making
the COLA calculation…
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…
T.C. Memo. 1997-348 — Estate of Leon Amiel, Deceased, Leon L. Amiel, Administrator, C.T.A. v. Commissioner IRCCourt RulingsJul 29, 1997
…edent's adjusted gross
estate. ERTA eliminated this limitation for persons dying after
December 31, 1981. The intent of Congress in repealing the marital
deduction quantitative limits was to treat a husband and wife as
one economic unit and to allow unlimited tax-free transfers within
that unit. S. Rept. 97-144, at 127…
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…
76 T.C. 433 — Ralph Gano Miller (Corp.) v. Commissioner IRCCourt RulingsMar 17, 1981
…e 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 employer sto…
IRCCourt RulingsJun 11, 1996related by meaning
g, we give effect to the
plain meaning of the words used therein and sustain respondent's
determination that petitioners are liable for the 10-percent additional tax under section 72(t).
We have considered petitioners' remaining arguments and find
them unpersuasive.
3. Conclusion
In order to give effect to our disposit…
PBGCPBGC Opinion LettersMay 20, 1998
…of
an owner. See,
e.g.,
PBGC
Opini on Let ter s No.
83-16 (July 12, 1983), No . 81-40 (Decem ber 9, 1981), N o. 81-37 (No vember 16, 19 81),
No.
81-31 ( Septembe r 22, 1981), No. 81-30
(Sep temb er 22 ,
1981), No. 81-13 ( May 13, 1981) , No. 79- 6, (Apr il 10,
1979), N o. 78-25 (Octob er 31, 1978), N o. 77-152 (July 13…
81 FR 8832 — Regulations Governing Organization of the Joint Board for the Enrollment of Actuaries Joint BoardFinal Rules (FR)Feb 23, 2016
…s, and the Secretary is to be elected from among the Labor Department representatives. On April 27, 1981, the Secretaries of Treasury and Labor approved restated Bylaws of the Joint Board (the 1981 Bylaws). Sections 3(b) and 3(c) of the 1981 Bylaws provide that the Chairman and Secretary, respectively, will be elected …
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…
IRCCourt RulingsAug 13, 1990related by meaning
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 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…
IRCCourt RulingsOct 28, 1987
…ctice and Procedure.↩ 2. The House committee report contains similar language. See H. Rept. 97-201 (1981), 1981-2 C.B. 352↩, 379-380. See also Staff of Joint Comm. on Taxation, General Explanation of the Economic Recovery Tax Act of 1981, at 239-240 (J. Comm. Print 1981).
3. See note 2 supra↩, and accompanying text.
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…
IRCCourt RulingsJul 31, 2000related by meaning
red all of petitioners’
arguments for contrary holdings; those arguments not discussed
herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent
necessary to reject or sustain each determination . We also have
considered all of respondent’s arguments a…
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…
REG-130241-04 — Proposed regulations under section 415 of the Code contain proposed amendments to regulations regarding limitation on benefits and contributions under qualifie… IRCProposed Rules (FR)Proposed Jul 5, 2005
…sation under section 415(c)(3). Comprehensive regulations regarding section 415 were last issued in 1981. See T.D. 7748, 1981-1 C.B. 259, published in the Federal Register on January 7, 1981 (46 FR 1687). Since then, changes to section 415 have been made in the Economic Recovery Tax Act of 1981, Public Law 97-34 (95 St…
IRCCourt RulingsApr 26, 2005related by meaning
…ns and to fashion equitable
remedies tö resolve these controversies." Simmons v.
Commissioner, T.C. Memo. 1995-422; see also Stevens v. Commissioner, T.C. Memo. 1985-192; Wenzel v. Commissioner, T.C.
Memo. 1982-595, affd. 707 F.2d 694 (2d Cir. 1983). Rather, in a
declaratory judgment action under section 7476, we must …