Search the Pension Law Library

1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …that it included the amendments made on January 22 and 29, 1969. 26 C.F.R. sec. 1.482-2 (1970). The 1971 revision of the Code of Federal Regulations codifi e d regulations as of January 1, 1971, including ame ndments published during 1970. See 26 (p art 1 (secs. 1.401-1.500)) C.F.R. i, v (1971). This 1971 revision cont…
2. 63 T.C. 386 — Estate of Stefanowski v. Commissioner
   IRCCourt RulingsDec 19, 1974
   …n Fund A. These items were sold and the proceeds reinvested in short-term Treasury bills by March 1,1971. On March 25, 1971, the trustees of the plan made a pro rata cash distribution of all the assets of the plan to the participants or their beneficiaries. Petitioner, as decedent’s designated beneficiary (section 9 of…
3. 67 T.C. 878 — Blyler v. Commissioner
   IRCCourt RulingsFeb 28, 1977
   pril 1, 1971, and since that time he has not been employed by either Howe & French, Inc., or Landsverk Corp. or any of its subsidiaries or affiliates. In January 1971 petitioner learned that the pension trust was to be terminated due to the decline in profits of Howe & French, Inc., and Landsverk. Upon application (app…
4. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
   IRCCourt RulingsMar 6, 2001★ strong match
   ciency, id. , petitioner cites Chrysler Corp. v. Brown , 441 U.S. 281 (1979), for the proposition that respondent’s reopening procedures in Rev. Proc. 94-68, 1994-2 C.B. 803, should have “the force and effect of law”. Chrysler Corp. v. Brown , 441 U.S. at 302 (quoting Morton v. Ruiz , 415 U.S. 199, 232, 235, 236 (1974)…
5. 69 T.C. 97 — Feroleto Steel Co. v. Commissioner
   IRCCourt RulingsOct 25, 1977
   …payments of Payments of repayment principal interest Dec. 1969.0 $2,656 Dec. 1970.0 10,625 Dec. 28, 1971 .$125,000 10,625 125,000 23,906 Late in 1971 the trustees asked Mr. Smith to ascertain from Seaboard the amount of repayment of the loan and the possibility of repaying the loan over a period of four quarters. Mr. S…
6. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
7. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
   IRCCourt RulingsJul 22, 1980related by meaning
   …etermination letters shall have limited application * * * See also Vernaccini v. Commissioner, T.C. Memo. 1974-66.
8. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
   IRCCourt RulingsNov 7, 1996related by meaning
   is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
9. 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
   ed do not apply to requests for any documents to the extent § 6104 applies. Statement identifying information to be deleted from public inspection .04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
10. 71 T.C. 32; 1 Employee Benefits Cas. (BNA) 2040 — Thompson v. Commissioner
    IRCCourt RulingsOct 12, 1978related by meaning
    do not deal with the operations of the plan, there is a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comm…
11. 73 T.C. 779 — Woodson v. Commissioner
    IRCCourt RulingsFeb 5, 1980
    . Woodson, deceased. Petitioners filed their joint Federal income tax return for 1971 with the Director, Internal Revenue Service Center, Austin, Tex. Curtis B. Woodson and Edna Woodson, married in 1973, filed joint income tax returns for 1973 and 1974 with the Director, Internal Revenue Service Center, Austin, Tex. On…
12. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    IRCPrivate Letter RulingsMar 3, 2000related by meaning
    …C:EBEO:4 TL-N-4712-99 UILC: 419.00-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR FROM: Assistant Chief Counsel (Employee Benefits and Exempt Organizations) CC: EBEO SUBJECT: This Field Service Advice is in res ponse to your memorandum dated October 5, 1999. Field Service Advice is not …
13. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    …rement interest 5% 5% 5% Salary scale -0--0--0- Pre-retirement turnover -0--0--0- Mortality (males) 1971 IAM-2 1971 IAM-2 1971 IAM-2 Mortality (females) 1971 IAM-8 1971 IAM-8 1971 IAM-8 Form of benefit , , For purposes of these calculations, Matthews used the following data for Davis: Date of birth . 5/7/34 Date of spo…
14. 67 T.C. 906 — Jennemann v. Commissioner
    IRCCourt RulingsMar 7, 1977
    OPINION Hall, Judge: Respondent determined a $557.91 deficiency in petitioners’ 1971 income tax. The issues for decision are: (1) Whether this Court is prohibited from taking action herein since it is not established pursuant to the provisions of article III of the Constitution. (2) Whether section 402(a)(2) as applica…
15. Treas. Reg. § 1.401(a)(4)-12(4) — Definitions.
    IRCRegulationsMay 18, 2016
    …ality Table (1983 IAM) (Female); the 1983 Individual Annuity Mortality Table (1983 IAM) (Male); the 1971 Group Annuity Mortality Table (1971 GAM) (Female); the 1971 Group Annuity Mortality Table (1971 GAM) (Male); the 1971 Individual Annuity Mortality Table (1971 IAM) (Female); or the 1971 Individual Annuity Mortality …
16. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    IRCCourt RulingsDec 30, 1998
    …t respondent has agreed to. The claimed costs and improvements still in dispute relate to the years 1971 through 1986, for which petitioner has minimal or no documentation. Respondent argues that petitioner's testimony as to the costs of the claimed improvements is self-serving and uncorroborated. Petitioner claims tha…
17. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998related by meaning
    …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 (…
18. 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 …
19. 70 T.C. 158 — Ma-Tran Corp. v. Commissioner
    IRCCourt RulingsMay 4, 1978
    …ar 1973 he submitted vouchers covering $7,569.14 and charged back $2,050. During the calendar years 1971, 1972, and 1973 Huffaker received advances for travel and entertainment expenses and submitted vouchers for travel and entertainment expenses as follows: Year Advances Vouchers Difference 1971 .$6,900 $4,305.55 $2,5…
20. 83 T.C. 154; 83 T.C. No. 10 — Tipton & Kalmbach, Inc. v. Commissioner
    IRCCourt RulingsJul 25, 1984★ strong match
    …to the Tax Court Rules of Practice and Procedure. See Tipton & Kalmbach, Inc. v. Commissioner, T.C. Memo. 1982-260. We note, however, that Congress in enacting ERISA appears to have adopted the facts and circumstances test of sec. 1.401-6(b)(2), Income Tax Regs., for determining whether a partial termination has occurr…