IRCCourt RulingsMay 14, 2001related by meaning
…F.3d 390 (10th Cir. 2000).
The language of the decree also meets the requirement of 10
U.S.C. sec. 1408(a)(2)(C) (1994) for direct payment to petitioner
out of the retired pay of petitioner's former spouse:
in the case of a division of property, [the court
order] specifically [provides] for the payment of an
amount, ex…
ERISARegulationsJan 1, 2017
(c)(4)(iv) (iv) Employee A is employed on June 1, 1980 in service covered by a plan with a calendar year accrual computation period, and which requires 1,800 hours of service for a full accrual. Employee A completes 500 hours from June 1, 1980 to December 31, 1980, and completes 100 hours per month in each month during…
IRCCourt RulingsMay 31, 1989
…vision, if petitioner made a good-faith determination that it was exempt from taxation for 1979 and 1980, then the filing of information returns under section 6033 for those years would have started the running of the applicable periods of limitation. Respondent concedes that petitioner determined its tax-exempt status…
IRCCourt RulingsOct 9, 1990related by meaning
o. v. Commissioner, 30 T.C. 10, 22-23 (1958), affd. 267 F.2d 853 (7th Cir. 1959); Times Publishing Co. v. Commissioner, 13 T.C. 329, 335 (1949), affd. per curiam 184 F.2d 376 (3d Cir. 1950). Section 23(p) was reenacted as section 404 in the 1954 Code in essentially the same form. Don E. Williams Co. v. Commissioner, 42…
IRCCourt RulingsJun 1, 1987
… under section 4975(a) as follows:
Petitioner TYE Deficiency
Olga Lambos (Olga) 1976 1977 1978 1979 1980 1981 $228.00 684.00 1,140.00 1,596.00 2,052.00 2,508.00
Anton Lambos (Anton) and Olga Lambos 1976 1977 1978 1979 1980 1981 487.50 975.00 1.462.50 1,950.00 2.437.50 2,925.00
The issues for decision are (1) whether pe…
IRCCourt RulingsJun 25, 2012related by meaning
other grounds, and
remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206;
Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 -
II. Administrative Costs
The administrative costs at issue are costs that petitioner incurred from the .
time respondent issued the notice of deficiency up to the …
IRCCourt RulingsMay 9, 1988
…denied the Teamsters Fund’s motion to vacate the April 29, 1975, judgment. Subsequently, in January 1980, the Teamsters Fund moved for leave to renew their motion to vacate the April 29, 1975, judgment and also sought to vacate the April 12, 1977, order and supplemental judgment. By orders, dated July 21, 1980, and Aug…
IRCCourt RulingsDec 16, 1998related by meaning
xcise tax returns could have concluded that the relevant
transfer was not a prohibited transaction, or, if it was, that
it had been corrected earlier. We have carefully considered all remaining arguments made
by the parties for holdings contrary to those expressed herein,
and, to the extent not discussed above, find th…
IRCCourt RulingsSep 29, 1992
…ddition to tax under section 6659A.
Robert Stephan, Jr., P.C. (Stephan) Stephan was incorporated in 1980 under the laws of the State of Arizona. Stephan timely filed its Forms 1120, U.S. Corporation Income Tax Returns, for the taxable years ending July 31, 1986, and July 31, 1987. Stephan’s taxable year for Federal inc…
IRCCourt RulingsNov 13, 1998related by meaning
…is
case would lie, stated in Roundy v. Commissioner
, 122 F.3d 835,
837 (9th Cir. 1997), affg. T.C. Memo. 1995-298:
[Section 72(t)(1)] applies to any retirement
distribution, so long as it is not specifically
exempted and is from a "qualified retirement plan".
Petitioner has not disputed that the distribution in issue …
IRCCourt RulingsDec 24, 1985
…p. Regs, expand the use of voluntary employees’ beneficiary associations,” 53 J. Taxation 210, 211 (1980). In 1969, the Commissioner issued proposed regulations under section 501(c)(9). 34 Fed. Reg. 1028 (1969). Although the proposed regulations defined "other benefits” similarly to the definition in the final regulati…
IRCCourt RulingsMar 15, 2004related by meaning
tutory scheme itself suggests that other liberties should
not be indiscriminately inserted through the judicial process.
Cf. Larotonda v. Commissioner , 89 T.C. 287 (1987) (interpreting
former section 72(m)(5), a penalty provision without the list now
contained in section 72(t)(2), and largely limited to its facts
by o…
PBGCCode / StatuteJan 24, 2020
(h) (h) Applicability to nonforfeitable benefits accrued as of July 30, 1980; manner and extent of guarantee
(h)(1) (1) Except as provided in paragraph (3), subsections (b) and (c) shall not apply with respect to the nonforfeitable benefits accrued as of July 29, 1980, with respect to a participant or beneficiary under…
IRCCourt RulingsAug 22, 1994related by meaning
lso claimed a deduction for the actual costs of providing employee medical and life insurance benefits during the 1985 taxable year.
The 1986 Proposal On January 29, 1986, temporary regulations were issued under sections 419 and 419A. On February 6, 1986, Robert Dolgin sent a letter to Erwin Kantor, petitioner’s vice p…
PBGCCode / StatuteJan 6, 2017
(a) (a) Authority, time, and criteria Within one year after September 26, 1980, a multiemployer plan may irrevocably elect, pursuant to procedures established by the corporation, that the plan shall not be treated as a multiemployer plan for any purpose under this chapter or the Internal Revenue Code of 1954, if for ea…
IRCCourt RulingsJul 22, 1980related by meaning
en program properly communicated to employees in 1974, in that, it was not adopted until April 15, 1975, 3y2 months after the end of the taxable year. The provisions of section 401(b) of the Code do not apply to situations involving the existence of a plan * * *
Thereafter, on December 31, 1976, petitioner filed, with …