Search the Pension Law Library

1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …l such amounts cease to be deferrable under D’s method of accounting. 31 Fed. Reg. 10395. While the 1966 proposed regulations were in proposed form, the 1962 regulation remained in effect. 26 C.F.R. sec. 1.482-1 (1961 ed. 1965 Cum. Supp.). Meanwhile, two successive new editions of the Code of Federal Regulations were p…
2. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
   IRCRevenue ProceduresJan 2, 2013related by meaning
   P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
3. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
   IRCRevenue ProceduresJan 2, 2014related by meaning
   P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
4. 58 T.C. 115 — Doing v. Commissioner
   IRCCourt RulingsApr 25, 1972
   …you very much for your help. Sincerely, (S) Keith L. Doing Approximately 1 week later, on April 27, 1966, petitioner’s Facing Page of the New Plan and Application for Custodian, dated March 24, 1966, and the Open Account Application and Dividend Reinvestment Order, dated April 21,1966, were sent by petitioner’s adviser…
5. 57 T.C. 326 — Trebotich v. Commissioner
   IRCCourt RulingsDec 9, 1971
   eement expired on June 30, 1966, but in a 1966 agreement, the mechanization fund, the vesting benefit trust, and the welfare trust were all continued. Under the 1966 agreement, the employers were to contribute approximately $38 million to the mechanization fund, at the rate of $7.4 million per year. The PMA was to coll…
6. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
   IRCCourt RulingsMay 26, 1976
   …nd sterling was $2.40 and the commercial rate of exchange was $2.3835. Sometime prior to August 19, 1966, petitioner determined to inaugurate a private pension plan for its United Kingdom employees; the plan was to go into effect October 1,1966. Petitioner announced its intention to its employees on or about August 19,…
7. 77 T.C. 97; 2 Employee Benefits Cas. (BNA) 1678 — Miller v. Commissioner
   IRCCourt RulingsJul 23, 1981
   …Rept. 1707, 89th Cong., 2d Sess. (1966), 1966-2 C.B. 1059,1103. Also see Hall v. Commissioner, T.C. Memo. 1979-342.
8. 60 T.C. 227; 60 T.C. No. 27 — Tobey v. Comm'r
   IRCCourt RulingsMay 17, 1973
   attorney in Seattle. During 1964,1965, and 1966, except for three very short visits to the United States, petitioner was physically present in Europe. Petitioner filed Federal income tax returns on the cash basis for taxable years 1965 and 1966 with the Director of International Operations, Washington, D.C. Petitioner’…
9. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
   IRCCourt RulingsJan 31, 1973
   …cal year ended March 27, 1965, and increased the deduction claimed by petitioner in its fiscal year 1966 by $1,750, the difference between the $202,-696 deduction claimed by petitioner and the $204,446 actual payments for unused sick leave made by petitioner in its fiscal year ended March 26,1966. Eespondent explained …
10. 62 T.C. 456; 62 T.C. No. 51 — Latrobe Steel Co. v. Commissioner
    IRCCourt RulingsJul 3, 1974
    …y 1, 1965. 3. All those employees who were eligible on December 31, 1965, for a regular vacation in 1966, exclusive of those employees who became vested for the 13 weeks of vacation pay in 1964 or 1965 would be entitled to 13 weeks of extended vacation pay on January 1, 1966. 4. In addition, an employee who was not eli…
11. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    …stituted a modification of the terms of the notes. We have previously noted that a technical advice memorandum is merely a ruling given to a specific taxpayer based upon the taxpayer's specific facts and is not a ruling of general application. See Golden Belt Tel. Association, Inc. v. Commissioner , 108 T.C. 498, 506 (…
12. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    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 …
13. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
14. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    …red by the Joint Committee on Taxation (the Blue Book); privatd letter rulings and technical advice memoranda issued after October 31, 1976; actions on decisions and general counsel memoranda issued after March 12, 1981 (as well as general counsel memoranda published in pre-1955 volumes of the Cumulative Bulletin); Int…
15. 63 T.C. 11 — Gillis v. Commissioner
    IRCCourt RulingsOct 2, 1974
    …f debits and credits made to the “Retirement Income Plan” account on B-G’s books beginning March 31,1966: Date Entry Debit Credit Balance Mar. 31,1966 Accrual-receivable $22,900.31 0 $22,900.31 June 13,1966 Securities received 0 $24,998.84 (2,098.53) Aug. 31,1966 Securities received 0 5,003.30 (7,101.83) Mar. 31,1967 A…
16. 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…
17. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
18. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
19. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983
    …y or factory-like setting in part by supervised employees. See S. Rept. 1707, 89th Cong., 2d Sess. (1966), 1966-2 C.B. 1059, 1103 (1966); Tobey v. Commissioner, 60 T.C. 227, 234 (1973); Van Dyke v. United States, supra. “Sec. 911(b) provides in part as follows:
20. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    dicated , statutory references are to the Internal Revenue Code , Title 26 U.S.C. (Code), in effect at all relevant times , Rule references are to the Tax Court Rules of Practice and Procedure , and monetary amounts are rounded to the nearest dollar. Served 07/11/24 2 [* 2 ] U.S. Railroad Retirement Board (RRB) in 2015…