Search the Pension Law Library

41. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017
    …tory, creating no legally enforceable rights for taxpayers. See, e.g., Greene v. Commissioner, T.C. Memo. 1992-202, 1992 Tax Ct. Memo LEXIS 239; Tucker v. Commissioner, T.C. Memo. 1983-210, 1983 Tax Ct. Memo LEXIS 578; Chapman v. Commissioner, T.C. Memo. 1982-68, 1982 Tax Ct. Memo LEXIS 675; see also Marks v. Commissio…
42. 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…
43. 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…
44. Treas. Reg. § 1.72-4(d)(3)(v) — Exclusion ratio.
    IRCRegulationsJul 26, 2016
    …le year 1993, to redetermine amounts to be received as an annuity under the contract as of June 30, 1992. The extent to which the amounts received in 1993 or thereafter shall be considered amounts received as an annuity is determined as follows: Pre-July 1986 investment in the contract allocable to taxable years 1991 a…
45. 29 C.F.R. § 4022.61(f) — Limitations on benefit payments by plan administrator.
    PBGCRegulationsJan 1, 2017
    …ruptcy termination, see §§ 4022.21(e), 4022.22(b), and 4022.23(g).) Example 1. Facts.On October 10, 1992, a plan administrator files with the PBGC a notice of intent to terminate in a distress termination that includes December 31, 1992, as the proposed termination date. A participant who is in pay status on December 3…
46. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. GEORGE H. ROBINSON, ADMINISTRATOR ANSWERING SERVICE, INC. ESOP
    ERISACourt RulingsFeb 2, 1993
    14, 1992, certain special procedural rules were prescribed for the presentation of evidence and argument by the parties in written form. In accordance with those procedural rules, Respondent's opening statement dated April 2, 1992, with attached Exhibits "A" through "I"; Pt/BA's opening statement dated May 24, 1992, wi…
47. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    … however, there was no levy by respondent in this case. Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13, affd. without published opinion 166 F.3d 1201 (2d Cir. 1998), also cited by petitioner, the taxpayer was indicted on charges of violating Federal currency transaction reporting laws. As part of the taxpaye…
48. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. SPALDING AND EVENFLO COMPANIES, INC.
    ERISACourt RulingsFeb 1, 1993
    Respondent's statement of reasonable cause, due January 13, 1992, that was filed subsequent to January 13 if Respondent describes in the statement of reasonable cause what is intended to be produced and a reasonable time frame within which to produce these items. This letter was received on or about January 8, 1992. 1…
49. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
50. U.S. Tax Court — Cynthia M. Martinez v. Commissioner
    IRCCourt RulingsDec 29, 2008
    … 641 (9th Cir . 2008) (quoting United States v . Plummer 174 Bankr . 284, 286 (Bankr . C .D . Cal . 1992)) . Nonetheless, in reexamining the table supra page 5, we note that even accepting respondent's application as given, petitioner has paid more than her share of the liabilities for 1992 and 1995 . Further, if one w…
51. PLR 200610016 — Year of Deduction
    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…
52. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CINPAC, INC./LIBBY LEE TOYS, INC.
    ERISACourt RulingsMar 20, 1995
    …e Department [of Labor]." The Respondent was also notified of the 45-day time limit in the April 3, 1992, letter of rejection, which it received on April 7, 1992. Respondent sent in the requested additional information by letter of May 21, 1992; 48 days after the date of the April 3, 1992, Notice, but only 44 days afte…
53. 115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner
    IRCCourt RulingsNov 9, 2000
    …lified asset account, as defined in section 419A(a), was $64,615,936 5 for 1991 and $84,192,933 for 1992. The foregoing account limits for 1991 and 1992 included $53,313,236 and $71,602,395, respectively, attributable to a reserve for postretirement medical benefits. The Trust filed Forms 990, Return of Organization Ex…
54. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    …n and not as findings of fact in this case. See Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994). Petitioner resided in Washington when he petitioned this Court. Absent stipulation to the contrary, appeal of this case would apparently lie to the U.S. Court of Appeals for th…
55. T.C. Memo. 1998-30 — Brian J. Patrick v. Commissioner
    IRCCourt RulingsJan 26, 1998
    …ts a finding that the transactions did not create bona fide debt. Cf. Fuller v. Commissioner , T.C. Memo. 1980-370 (taxpayers submitted evidence that their net worth substantially exceeded the sum of - 15 - the balances on the promissory notes, and thereby demonstrated their ability to repay the obligation). e. The Rel…
56. T.C. Memo. 2003-32 — Howard E. Clendenen v. Commissioner
    IRCCourt RulingsFeb 12, 2003related by meaning
    d caselaw require that corrective actions must be taken to requalify a plan that has violated section 415. Martin Fireproofing v. Commissioner , supra at 1184; sec. 1.415-6(b)(6), Income Tax Regs. Petitioners provided calculations to establish that the plan was qualified as of the taxable year ending June 30, 1987. In …
57. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    …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…
58. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    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…
59. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ear. * * *. Moreover, no deduction is allowed with respect to a dividend paid. [H. Conf. Rept. 99-841, at 11-276 (1986), 1986-3 C.B. (Vol. 4) 1, 276.] Accordingly, we find that the Commissioner acted within her delegation of authority, and that section 1.56(g)-1(d)(3)(iii)(E), Income Tax Regs., harmonizes with the reve…
60. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…