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Go to T.C. Memo. 1973-15 (not yet in the library — opens the official source)
72 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  2. 70 T.C. 158 — Ma-Tran Corp. v. Commissioner
    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…
  3. 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…
  4. 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,…
  5. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    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…
  6. 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 (…
  7. 70 T.C. 24 — Keeler v. Commissioner
    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…
  8. 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. Some of the cited cases raise the question of the application of secs. 165(a) and 23(p), I.R.C. 1939, to a determination of the proper effective date of trust instruments adopted by accrual basis taxpayers…
  9. 73 T.C. 182 — Oakton Distributors, Inc. v. Commissioner
    IRCCourt RulingsOct 30, 1979★ strong match
    …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…
  10. 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…
  11. 89 FR 32346 — Amendment to Prohibited Transaction Exemptions 75-1, 77-4, 80-83, 83-1, and 86-128
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    nd in its text, PTE 2020-02 has been broadly amended to encompass compensation for advice irrespective of the product recommended. Back to Citation 6.  ERISA section 408(a) and Code section 4975(c)(2), expressly permit the Department (through the Reorganization Plan No. 4 of 1978) to grant “a conditional or uncondition…
  12. 73 T.C. 40 — La Fargue v. Commissioner
    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…
  13. 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…
  14. 111 T.C. No. 15 — John F. Romann v. Commissioner
    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…
  15. 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…
  16. 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))…
  17. 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…
  18. 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 …
  19. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…
  20. 73 T.C. 758 — Tionesta Sand & Gravel, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1980★ strong match
    … the amount of $9,960.59 in petitioner’s Federal income tax for its taxable year ended February 28, 1973. Due to a concession by petitioner, the sole issue presented for decision is whether petitioner’s profit-sharing plan and trust qualified under section 401(a) during its fiscal year ended February 28,1973. All the f…