IRCCourt RulingsFeb 9, 2023related by meaning
… and June
30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon
Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M.
(CCH) 1707 (a case involving tax years 1979, 1980, and
1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d
825 (5th Cir. 1996)
In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
IRCCourt RulingsMay 4, 1978
79.75
House . 702,40 43.30
2,372.10 323.05
Fiscal 1973
Huffaker.0 0
House . 903.41 0
903.41 0
These meal expenses were incurred in the Knoxville area. In addition, Ma-Tran advanced $13,700 and $25,950 to Huffaker for travel and entertainment expenses in fiscal years 1972 and 1973, respectively. Huffaker was required to…
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,…
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
, or documents to which §6104 (document open to public inspection) applies, as described in section 10.03.
Taxpayer may protest deletions not made
.05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
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
f the adopted TAM to the taxpayer, or at the end of the 30-day period following the issuance of the TAM to the field.
Discussion with the taxpayer
.03 EP or EO Technical will not discuss the contents of the TAM with the taxpayer or the taxpayer’s representative until the taxpayer has been given a copy by the EP or EO E…
68 T.C. 881 — Forsyth Emergency Services, P.A. v. Commissioner IRCCourt RulingsSep 12, 1977
…al Status Report,” with the Internal Revenue Service. During petitioner’s fourth year of operation, 1973, there were 10 full-time employees working as of December 31, 1973. Three of these full-time employees, Joyce H. Reynolds, David S. Nelson, and George Podgorny, were again allowed coverage by the plan. Wilcox had st…
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 (…
IRCCourt RulingsApr 17, 1978
h. Petitioners, cash basis taxpayers, filed their joint Federal income tax return for the year 1973 with the Central Service Center, Cincinnati, Ohio. During the calendar year 1973 Harry C. Keeler (hereinafter referred to as petitioner) retired from his position as an executive with the Michigan National Bank (hereinaf…
IRCCourt RulingsJul 22, 1980related by meaning
…etermination letters shall have limited application * * *
See also Vernaccini v. Commissioner, T.C. Memo. 1974-66.
IRCCourt RulingsDec 4, 1978★ strong match
…s contribution in 1972, the sum of $13,939 remained to be recovered tax-free under section 72(d) in 1973 and future years. In 1973, the year in issue, petitioner received Civil Service retirement payments of $18,801. On his 1973 return, petitioner excluded from income the first $5,200 received under section 105(d), as …
71 T.C. 1011 — Orthopedics International, Ltd., P.S. v. Commissioner IRCCourt RulingsMar 19, 1979
… $39,616.51 in excess of that year’s 10 percent of covered compensation normal cost of the plan. In 1973, 10 percent of the pension plan’s covered compensation equaled $83,819.59. Petitioner actually contributed this amount to the pension plan for that year and deducted the full contribution. In addition, in 1973 petit…
73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner IRCCourt RulingsJan 31, 1980★ strong match
…April 1979 determination letter. Because these arguments do not relate to the status of the plan in 1973, we do not discuss them.
Par. (7) was substantially rewritten by the Employee Retirement Income Security Act of 1974, Pub. L. 93-406,88 Stat. 829, applicable generally to taxable years beginning after Dec. 31, 1975.…
IRCCourt RulingsOct 10, 1979
972 payment was not made until December 29, but no penalty was included. In 1973, the trust paid petitioner $16,502 on July 6, more than a month late. Administration was lax in the other areas. Although petitioner gave the trustees the stock certificates when the annuity agreement was executed, no notice of the transfe…
IRCCourt RulingsAug 11, 1980
h 1973, Higgins claimed deductions for contributions made to the Higgins Trust based upon participants’ compensation as set out in the schedule below: Calendar year Participants’ compensation Higgins’ contribution Percentage
1968 $100,468.33 $15,000.75 15
1969 112,440.00 16,866.00 15
1970 138,781.60 20,817.24 15
1971 1…
73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner IRCCourt RulingsOct 30, 1979
…ct to the qualification of the plan on Dec. 15, 1972, before expiration of this period on Sept. 15, 1973, thus extending the period until 91 days after the Mar. 2, 1973, issuance of the final determination letter. Sec. 1.401(b)-1(d)(3)(i), Income Tax Regs. Because the requirements of sec. 1.401(b)-1(d)(3)(i), Income Ta…
IRCCourt RulingsNov 4, 1998
… 601(a) of S. 1179, relating to
declaratory judgment actions brought by employees.
On September 19, 1973, after the Senate completed action on
further amendments to S. 4, the Senate took up H.R. 4200, a bill
previously passed by the House of Representatives, and added the
language of S. 4, as amended, as an amendment a…
IRCRegulationsSep 9, 2016
…ed items: Computation of Earliest Base Unit Estimation Date Example Plan year (calendar year basis) 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 Plan A V V V V Contract 1 E/B E/B E/B E/B Base unit estimation date 1 1973 1973 1973 1976 1976 1979 1979 1979 1979 Plan B V V V V Contract 2 2 2 2 B* E/B E/B* C…
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…
67 T.C. 490 — Wisconsin Nipple & Fabricating Corp. v. Commissioner IRCCourt RulingsDec 16, 1976
…pensation of the hourly employees with at least 1 year of service were as follows:
In the summer of 1973, the petitioner’s corporate returns for its taxable years 1972 and 1973 were audited, and the petitioner, for the first time, was specifically told that the IRS was questioning the qualification of its profit-sharin…
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 …