T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
… 1,943,815 1,979,855
Inc.
2
Greenstone 305,000 250,000 377,051 367,000
Roberts
Adv.
3
Interpublic 1,652,525 1,705,044 1,635,232 1,437,983
Group of
Cos.
4
Laser N/A N/A N/A 109,826
Vision
Centers, Inc.
Omnicom Group 780,000 957,500 1,053,750 1,168,750
75th %tile 965,600 964,800 1,106,100 955,700
5
Regression Est.
1
Empl…
IRCCourt RulingsApr 25, 1972related by meaning
ain in existence, and all of the provisions of this agreement shall remain in force, other than the provisions relating to the Employer contributions. All of the assets of the account on hand on the date specified in such notice shall be held, administered and distributed by the Custodian in the manner provided in this…
IRCCourt RulingsMay 19, 1986related by meaning
4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549.
Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
IRCCourt RulingsSep 25, 1996
…ip return for 1987, MIT 86 reported partnership taxable income of
$4,855,505, which consisted of $4,652,314 (the deferred income
that it reported due to the change in accounting method), plus
$203,191, which it called fee income and which represented the
accrual of interest payable from MPC, and no expenses.
For the ye…
IRCCourt RulingsAug 3, 1987related by meaning
performance of services, including selection of assignments. Petitioner or the worker may terminate the COE by giving the other party written notice. On May 27, 1986, respondent issued a final adverse determination letter for the plan years ended October 31, 1982, 1983, 1984, and 1985 with respect to the Rodney D. Swa…
IRCCourt RulingsNov 26, 2007
…that there is no genuine
issue as to any material fact. Morrison v. Commissioner
, 81 T.C.
644, 651-652 (1983).
Based upon our review of the record, we are satisfied that
there is no genuine issue of material fact and that respondent is
entitled to judgment as a matter of law. The deficiencies in
this case arise from p…
IRCCourt RulingsDec 31, 1957related by meaning
y its shareholders, partners, or beneficiaries.
Sec. 430 (e) (1).
As stipulated.
Sec. 430 (e) (2) (B).
Sec. 430 (e) (2) (B) (1).
Sec. 445 (g) (2) (B). Sec. 503 (a) (1), made applicable by sec. 445 (g) (3).
IRCCourt RulingsMay 27, 2004
…lified person of the income or assets
of a plan”.
3
See O’Malley v. Commissioner
, 96 T.C. 644, 651-652
(1991), affd. 972 F.2d 150 (7th Cir. 1992). Under section
4975(c)(1)(E), each of the three loans also was a direct or
indirect “act by a disqualified person who is a fiduciary whereby
he deals with the income or asse…
29 T.C. 737 — R. G. Le Tourneau, Inc. v. Administrator of General Services IRCCourt RulingsJan 30, 1958related by meaning
cated to it. The division between the petitioner and the Georgia company was based on a mathematical formula that is set out as part of the agreement. By agreements dated December 1,1944, and March 26,1945, between the petitioner and the United States it was agreed that $3,900,000 of the profits realized by the petitio…
115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000
…The parties stipulated that the Trust’s account limit for
1991, as defined in sec. 419A(c), was $65,652,991. However, that
stipulation is contrary to the record in this case. The record
establishes, and we have found, that that account limit was
$64,615,936. We may, and we shall in this instance, disregard a
stipulatio…
IRCCourt RulingsJun 24, 2003related by meaning
tract unless such amounts are
specifically excluded from gross income under other provisions of
chapter 1 of the Code. The burden is on petitioners to demonstrate that the payments in question fall into a specific
statutory exclusion. See Commissioner v. Glenshaw Glass Co.
, 348
U.S. at 429-431.
Under section 72(t), a …
54 T.C. 1057 — Bernard McMenamy, Contractor, Inc. v. Commissioner IRCCourt RulingsMay 25, 1970
…26, restated in Rev. Rul. 68-654, 1968-2 C.B. 179; and P.S. No. 28 (1944), restated in Rev. Rul. 68-652, 1968-2 C.B. 176. In these rulings, he made clear that in his opinion, prohibited discrimination occurs when, as a result of using the years of service, the ratio between the employer contributions allocated to the a…
IRCCourt RulingsJul 25, 1974related by meaning
ew principal place of work.
Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217.
SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
IRCCourt RulingsJun 10, 2002related by meaning
T.C. Summary Opinion 2002-66
UNITED STATES TAX COURT
MILAGROS Z. GUECO, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 545-01S. Filed June 10, 2002.
Milagros Z. Gueco, pro se.
James N. Beyer
, for respondent.
DINAN, Special Trial Judge
: This case was heard pursuant to
the provisions of section …
IRCCourt RulingsAug 22, 1994
…fits Total Percent
Normal cost $351,815 $1,057,021 $1,408,836 O Accrued liability: Active employees 652,308 1,710,610 2,362,918 CD
Retirees 8,892,721 22,637,914 31,530,635 CO 05 00
9,896,844 25,405,545 35,302,389
Petitioner contributed $35,300,000 to the VEBA trust on December 29, 1986. Petitioner claimed a deduction f…
50 T.C. 771 — New England Tank Industries, Inc. v. Commissioner IRCCourt RulingsAug 26, 1968related by meaning
ale was not intended by the parties. See Breece Veneer & Panel Co. v. Commissioner., 232 F. 2d 319, 322 (C.A. 7, 1956), reversing 22 T.C. 1386 (1954). Haggard v. Commissioner, 241 F. 2d 288 (C.A. 9, 1956), affirming 24 T.C. 1124 (1955), and Beus v. Commissioner, 261 F. 2d 176 (C.A. 9, 1958), affirming 28 T.C. 1133 (195…
IRCCourt RulingsMar 27, 1963
…years indicated For each $1,000 of face amount; cash or loan value
1_ __ $623.23
2_ __ 637.58
3_ __ 652.35
4_ __ 667.57
5_ __ 683.23
6_ __ 699.36
7_ __ 715.96
8_ __ 733.08
9_ __ 750.74
10_ __ 768.97
11_ __ 787.82
12_ __ 807.35
13_ __ 827.61
14_ __ 848.70
15_ __ 870.71
16_ __ 893.76
17_ __ 918.01
18_ __ 943.64
19_ __ 97…
IRCCourt RulingsMar 31, 1961
… 809. 13
Subtotal_ 314, 395. 38
Administration expense at 3.3%_ 25, 743. 31
50% of net income_ 288, 652. 07
15% of adjusted gross income from feldspar_ 50, 377. 70
5% of adjusted gross income from sand_ 1, 067. 66
Total percentage depletion_ 71, 445. 36
Allowable depreciation_ 71, 445. 36
Pacific Geove, California, Pro…
122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner IRCCourt RulingsFeb 9, 2004related by meaning
oyer whose employees are
covered by the plan described in paragraph
(1), or
(ii) any authorized officer of the
cooperative described in paragraph (1), consenting to the application of sections 4978 and
4979A with respect to such employer or
cooperative.
* * * * * * *
(c) Definitions; Special Rules. * * *
* * * * * * *
…
IRCFinal Rules (FR)Jul 19, 2024
…
26,482
519,151
2031
864,291
529,534
524,342
26,760
502,774
2032
819,740
512,829
507,801
27,177
485,652
2033
775,430
495,365
490,509
27,438
467,927
2034
731,620
477,286
472,606
27,853
449,433
1
$1,000,000 death benefit reduced 4.55 percent for withdrawal during 2028.
( printed page 58928)
2
Notional account balance a…