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Go to T.C. Memo. 1992-533 (not yet in the library — opens the official source)
68 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
  2. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998
    iency Sec. 4971(b) Deficiency Sec. 6651(a) 1991 $772 --- $193 1992 1,310 $12,604 327 1993 3,250 31,999 812 1994 3,042 53,624 --- 1995 5,362 53,624 804 The second notice determined Federal excise tax deficiencies pursuant to section 4975 and additions to tax pursuant to section 6651 for 1992-95 (the second deficiency no…
  3. 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,
  4. 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…
  5. U.S. Tax Court — Susan Elizabeth Machlay v. Commissioner
    IRCCourt RulingsFeb 10, 2009related by meaning
    ic v . ,Commissioner , T .C . Memo . 1992-- 609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . . In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her medical condition . She explained at trial that although she received treatment from doctors in 2005, she did …
  6. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
  7. 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…
  8. 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…
  9. 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…
  10. 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…
  11. 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…
  12. 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…
  13. 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…
  14. 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…
  15. 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…
  16. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    , Pub. L. 100-647,102 Stat. 3342. No inferences as to whether or not earlier regulations are valid should be drawn from the amendment of sec. 7805(e). As noted in the facts, petitioner had 34 employees on Jan. 31, 1986, but paid bonuses to only 33 employees because one employee left the company prior to the date of pay…
  17. 70 T.C. 214; 1 Employee Benefits Cas. (BNA) 1835 — Automated Packaging Systems, Inc. v. Commissioner
    IRCCourt RulingsMay 15, 1978related by meaning
    …ards provisions of ERISA. 29 Fed. Reg. 56462 (1976). Ets-Hokin & Galvan, Inc. v. Commissioner, T.C. Memo. 1962-136. The term “period of severance” is defined under sec. 2530.200b-9(a)(3)(v) as follows:
  18. 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…
  19. PLR 199940014 — Year of Inclusion in Gross Income
    IRCPrivate Letter RulingsOct 8, 1999related by meaning
    … 10/8/1999 UILC: 457.01-00 457.05-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SE RVICE ADVICE MEMORANDUM FOR FROM: Assistant Chief Counsel (Employee Benefits and Exempt Organizations) SUBJECT: This Field Service Advice responds to your memorandum dated April 6,1999. Field Service Advice is not binding on Examinat…
  20. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    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’ …