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Go to T.C. Memo. 1975-341 (not yet in the library — opens the official source)
67 documents · 0.45sAllIRCERISAPBGCJoint 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. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980★ strong match
    …t. 2, 1974] Petitioner also refers to the plan in St. Joseph Bank & Trust Co. v. Commissioner, T.C. Memo. 1975-182. Respondent made no argument that in any event the adoption of a plan on Apr. 15, 1975, was untimely. However, sec. 401(b), I.R.C. 1954 (n. 15 supra), limits retroactive changes in profit-sharing plans to …
  3. 78 T.C. 930; 78 T.C. No. 66 — Hauser v. Comm'r
    IRCCourt RulingsJun 9, 1982
    …e nonforfeitable.” Sec. 1.219-l(c)(l)(ii)(A), Proposed Income Tax Regs., 40 Fed. Reg. 7661 (Feb. 21,1975). Petitioner satisfies none of these definitions because he was ineligible to receive any benefits under the 1975 rules. To get a benefit under the 1975 rules, an employee had to work for the company for at least 10…
  4. 70 T.C. 785 — Collins v. Commissioner
    IRCCourt RulingsAug 29, 1978
    … Loan Association in Nashville. On the same day she deposited $500 to that account. During the year 1975, as reported on their Federal income tax return, petitioner earned $4,729.03. She was employed during that year as a beauty operator by a beauty salon in Nashville and was compensated on a commission basis. Fifteen …
  5. 73 T.C. 1142 — Home Interiors & Gifts, Inc. v. Commissioner
    IRCCourt RulingsMar 24, 1980
    232 8,054,746.00 4,105,409 1975 97,583,835 12,739,821.00 6,858,947 1976 141,912,127 23,418,981.00 12,175,105 1977 168,944,103 27,330,113.00 14,416,901 From 1968 through 1975, gross sales increased almost 23 times, pre-tax earnings rose about 108 times, and after-tax earnings rose more than 114 times. During such period…
  6. 74 T.C. 1057 — Johnson v. Commissioner
    IRCCourt RulingsAug 12, 1980
    …come tax return the $119.86 of interest earned by the IRA. No interest was earned by the IRA during 1975. Petitioners argue that the excise tax under section 4973 should not be imposed on them (1) for 1975, because they took no income tax deduction for the 1975 contribution and (2) for 1976, because they included in th…
  7. 76 T.C. 1048 — Arkin v. Commissioner
    IRCCourt RulingsJun 25, 1981
    …Systems, Inc., purchased the property at the foreclosure sale for $1,000. During the years 1974 and 1975, petitioner was a partner in a law partnership known as Meyer, Weiss, Rose & Arkin. The partnership reported its income on a fiscal year ended March 31. In December of 1975, the partnership was dissolved and filed a…
  8. 82 T.C. 686; 82 T.C. No. 53 — Holswade v. Commissioner
    IRCCourt RulingsApr 26, 1984
    …ghtclub acts, or gambling casinos. Traveling by airplane, George and Fern left New York on July 17, 1975, arrived at Bergen, Norway, on July 18, 1975, and boarded the Stella Maris on July 18, 1975. The Stella Maris sailed from Bergen on July 18, 1975, and docked at Stockholm, Sweden, on July 31, 1975. On August 1, 1975…
  9. 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))…
  10. 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,…
  11. 77 T.C. 1096 — Cobb v. Commissioner
    IRCCourt RulingsNov 12, 1981
    … The Commissioner determined deficiencies in the petitioners’ Federal income taxes of $1,850.54 for 1975 and $795.58 for 1976. Also, for 1975, he determined an addition to tax under section 6653(a) of the Internal Revenue Code of 1954 of $92.53. After concessions by the petitioners, the issues for decision are: (1) Whe…
  12. 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 (…
  13. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    …76 and 7428 be similar. See S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 624-627); H. Rept. 94-658 (1975), 1976-3 C.B. (Vol. 2) 975, 976, 978; Joint Comm, on Taxation, 94th Cong., 2d Sess., General Explanation of the Tax Reform Act of 1976,1976-3 C.B. (Vol. 2) 413^116. Respondent’s answer in each one of those cases was…
  14. 89 FR 32122 — Retirement Security Rule: Definition of an Investment Advice Fiduciary
    ERISAFinal Rules (FR)Apr 25, 2024
    …ce of advice with respect to that plan account. Therefore, the Department does not believe that the 1975 regulation's five-part test is the only test that can properly define an investment advice fiduciary under the statute, and the Department does not believe its authority to revisit the regulatory definition of an in…
  15. 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…
  16. 71 T.C. 991 — Woodford v. Commissioner
    IRCCourt RulingsMar 12, 1979
    .C. secs. 8337 and 8339. During 1975, petitioner received 12 monthly payments totaling $10,879. On February 7,1976, petitioner became 70 years of age. At the time of his retirement in 1973, petitioner had contributed $12,284 into the Civil Service Annuity Fund (the fund). For purposes of this case, the parties have sti…
  17. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988related by meaning
    e technical advice memorandum referred only to the September 28, 1976, determination, and not to the determination request made on September 11, 1978. By letter, dated December 26, 1978, the Brooklyn District Director’s Office again advised petitioners that it was the District Director’s position that all interested pa…
  18. ERISA § 407(c)(2) (29 U.S.C. § 1107) — Limitation with respect to acquisition and holding of employer securities and employer real property by certain plans
    ERISACode / StatuteJan 6, 2025
    …or purposes of this subsection, in the case of an employer security held by a plan after January 1, 1975, the ownership of which is derived from ownership of employer securities held by the plan on January 1, 1975, or from the exercise of rights derived from such ownership, the value of such security held after January…
  19. Treas. Reg. § 1.408-4(c)(4) — Treatment of distributions from individual retirement arrangements.
    IRCRegulationsMay 18, 2016
    …The provisions of this paragraph may be illustrated by the following example: Example.On January 1, 1975, A, age 55, who is a calendar-year taxpayer, contributes $1,500 to an individual retirement account established for his benefit. For 1975, A is entitled to a deduction of $1,400 under section 219. For 1975, A does n…
  20. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    IRCCourt RulingsJun 18, 1997related by meaning
    … years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-277 UNITED STATES TAX COURT MARGARET M. MERKER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 26855-95. Filed June 18, 1997. Margaret M. Merker, pro se. Marjory A. Gilbert , for respon…