IRCRegulationsSep 9, 2016
…is a member of the top-100 employees within the meaning of paragraph (a)(2)(ii) of this A-3 for the 1987 year and 1990 year, the results are as follows: Year Compensation Status Comments 1986 $45,000 N/A Although prior to 414(q) effective date, 1986 constitutes the look-back year for purposes of determining the highly …
ERISARegulationsJan 1, 2017
…ice credited to the employee for vesting. The employee is re-employed by the employer on January 1, 1987 completing an hour of service on that date. Under § 2530.200b-4(b)(1), therefore, January 1, 1987 is the employee's reemployment commencement date. In 1987, the employee completes the number of hours of service requ…
90 FR 28004 — Removal of Interpretive Bulletins Relating to the Employee Retirement Income Security Act of 1974 ERISAFinal Rules (FR)Jul 1, 2025related by meaning
977) (“The attention of interested parties is directed to the fact that regulation 2550.408c-2 replaces Interpretive Bulletin 75-6”).
Back to Citation 7.
41 FR 3289 (Jan. 22, 1976).
Back to Citation
8.
43 FR 47713 (Oct. 17, 1978). Congress subsequently ratified Reorganization Plan No. 4 in 1984. See Sec. 1, Public La…
IRCCourt RulingsFeb 10, 1997related by meaning
to section 413(b)(7), the
District Court rejected the IRS argument, as phrased by the
court, "that by taking more of a deduction for the 1989 tax year than had been anticipated, AFC interfered with other employers'
ability to estimate the plan-wide deductible limit". Airborne
Freight Corp. v. United States
, 76 AFTR 2d…
IRCCourt RulingsMay 3, 1995
… deduction for the balance in the amount of $1,025,021 ($1,705,633 - $680,612) for the taxable year 1987. The financial statements of the National Presto VEBA for the taxable years 1983, 1984, and 1985 state that, for those years, the VEBA did not have investment income because “the Plans fund benefits paid and expense…
IRCCourt RulingsOct 20, 1998related by meaning
…r the year at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
T.C. Memo. 1998-379
UNITED STATES TAX COURT
DALE REID EDMONDS, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11916-97. Filed October 20, 1998.
Dale Reid Edmonds, pro se.
J. Craig Young
, for responden…
IRCCourt RulingsSep 29, 1992
the compensation to be $34,000 and $70,000 for 1986 and 1987, respectively.
The following is an annual benefit accrual schedule for the Stephan plan: Year Compensation Annual benefit accrual at 3.9% of compensation Total accrued benefit before sec. 415 Sec. 415 limit if no further service Total accrued benefit used by…
79 FR 25667 — Benefits Payable in Terminated Single-Employer Plans; Limitations on Guaranteed Benefits; Shutdown and Similar Benefits PBGCFinal Rules (FR)May 6, 2014
…start of funding resulted in an increased loss to the insurance program.
Treatment of UCEBs in OBRA 1987
Congress first explicitly addressed UCEBs in funding reforms contained in the Pension Protection Act of 1987, enacted as part of Public Law 100-203, the Omnibus Budget Reconciliation Act of 1987 (OBRA 1987). The OBR…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
IRCCourt RulingsMar 28, 1994
…and 5500-C are sufficient returns for section 6651(a)(1) purposes. The forms filed by the trust for 1987 and 1988 are not in the record. Thus, petitioners have failed to prove that those returns contained sufficient data to calculate their excise tax liability. We have, however, taken judicial notice of the Form 5500-R…
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 …
76 FR 13304 — Benefits Payable in Terminated Single-Employer Plans; Limitations on Guaranteed Benefits PBGCProposed Rules (FR)Proposed Mar 11, 2011
…start of funding resulted in an increased loss to the insurance program.
Treatment of UCEBs in OBRA 1987
Congress first explicitly addressed UCEBs in funding reforms contained in the Pension Protection Act of 1987, enacted as part of Public Law 100-203, the Omnibus Budget Reconciliation Act of 1987 (OBRA 1987). The OBR…
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…
IRCCourt RulingsJun 18, 1999related by meaning
…to the extent expressly authorized by statute. See Judge v.
Commissioner
, 88 T.C. 1175, 1180-1181 (1987); Naftel v.
Commissioner
, 85 T.C. 527, 529 (1985). This Court's jurisdiction
- 8 -
to redetermine a deficiency in tax generally does not extend to
statutory interest imposed under section 6601. See Bax v.
Commissio…
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…
IRCPrivate Letter RulingsJun 11, 2004related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM
January 07, 2004
Number: 200424004
Release Date: 6/11/04
Third Party Contact:
Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04
CASE-MIS No.: TAM- 127815-03, CC:ITA:B07
Industry Director
------------------------------------------------
Taxpayer's Name…
IRCCourt RulingsMay 29, 1997related by meaning
…
prior years. Easter v. Commissioner
, 338 F.2d 968, 969-970 (4th
Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v.
Commissioner
, 55 T.C. 28, 32 (1970). We reject petitioners’
argument that an exception to this rule applies to disputes
involving $10,000 or less.
To reflect the foregoing,
Decision will be entere…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
he Service anticipate issuing and requests comments on the issues intended to be addressed by such guidance.
Announcement 2007-68 Announcement 2007-68 This document contains numerous corrections to the preamble of final regulations (T.D. 9321, 2007-19 I.R.B. 1123) setting forth guidance on the application of section 40…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …