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81 documents · 0.25sAllIRCERISAPBGCJoint 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. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989
    8), 1978-3 C.B. (Vol. 1) 181, 231; Staff of the Joint Committee on Taxation, General Explanation of the Revenue Act of 1978, p. 73 (Comm. Print 1979). Section 131(c) of R.A. 1978, 92 Stat. at 2782 made the amendments contained in section 131(a) of R.A. 1978 effective for taxable years beginning after December 31, 1978.…
  3. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983★ strong match
    …, 805-806 (1979), revd. on other grounds 671 F.2d 167 (6th Cir. 1982); Kipnis v. Commissioner, T.C. Memo. 1982-471. Sec. 1348(b)(1)(A), as it stood for the years before 1979, imposed a mechanical 30-percent cap on self-employment income that could be treated as compensation if capital was a material income-producing fa…
  4. 78 T.C. 930; 78 T.C. No. 66 — Hauser v. Comm'r
    IRCCourt RulingsJun 9, 1982
    …that the plan as of October 1, 1976, was a qualified plan within the meaning of section 401(a). The 1978 rules defined the term participant to mean: any eligible employee who (i) shall have completed at least one year of continuous service, (ii) shall have attained the age of 25, and (iii) from time to time during whic…
  5. 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,…
  6. 75 FR 41600 — Reasonable Contract or Arrangement Under Section 408(b)(2)-Fee Disclosure
    ERISAFinal Rules (FR)Jul 16, 2010
    …8 FR 5374 (Feb. 3, 2003). Sec. 2550.401b-1 also issued under sec. 102, Reorganization Plan No. 4 of 1978, 43 FR 47713 (Oct. 17, 1978), 3 CFR, 1978 Comp. 332, effective Dec. 31, 1978, 44 FR 1065 (Jan. 3, 1978), 3 CFR, 1978 Comp. 332. Sec. 2550.401c-1 also issued under 29 U.S.C. 1101. Sec. 2550.404c-1 also issued under 2…
  7. 81 T.C. 1; 81 T.C. No. 1 — Anthes v. Commissioner
    IRCCourt RulingsJul 5, 1983★ strong match
    behalf for the plan year ending September 30, 1978. A contribution of $602 was made on petitioner’s behalf for the plan year ending September 30,1979. Petitioner established an Individual Retirement Custodial Account for 1978 with the Provident Institution for Savings, Boston, Mass, by making a contribution of $1,500 o…
  8. 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 (…
  9. 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…
  10. 75 FR 64910 — Fiduciary Requirements for Disclosure in Participant-Directed Individual Account Plans
    ERISAFinal Rules (FR)Oct 20, 2010
    …8 FR 5374 (Feb. 3, 2003). Sec. 2550.401b-1 also issued under sec. 102, Reorganization Plan No. 4 of 1978, 43 FR 47713 (Oct. 17, 1978), 3 CFR, 1978 Comp. 332, effective Dec. 31, 1978, 44 FR 1065 (Jan. 3, 1978), 3 CFR, 1978 Comp. 332. Sec. 2550.401c-1 also issued under 29 U.S.C. 1101. Sections 2550.404c-1 and 2550.404c-5…
  11. 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…
  12. REG-142695-05 — Proposed regulations under section 125 of the Code provide guidance on cafeteria plans. EE-16-79, EE-130-86, REG-243025-96, and REG-117162-99 withdrawn. Rev. R…
    IRCProposed Rules (FR)Proposed Sep 24, 2007
    …extent the employee could have elected taxable benefits. S. Rep. No. 1263, 95th Cong., 2d Sess. 74 (1978), reprinted in 1978 U.S.C.C.A.N. 6837; H.R. Rep. No. 1445, 95th Cong., 2d Sess. 63 (1978); H.R. Conf. Rep. No. 1800, 95th Cong., 2d Sess. 206 (1978). The legislative history also provides: [G]enerally, employer cont…
  13. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    of Claims, or the district court of the United States for the District of Columbia may make a declaration with respect to such initial qualification.” It is clear that Congress intended that the procedures under secs. 7476 and 7428 be similar. See S. Rept. 94-938 (1976), 1976-3 C.B. (Vol. 3) 624-627); H. Rept. 94-658 (…
  14. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992
    …limitations of section 404, i.e., are treated “as if there were such a plan.” Sec. 404(b). Prior to 1978, the deduction-timing rules for deferred compensation applied only to payments to employees, not to independent contractors. In 1978, Congress extended the rules regarding the deductibility of deferred compensation …
  15. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988
    …that proper notice had been given to all interested parties in accordance with the technical advice memorandum issued by the National Office on that same date. The trustees of the Teamsters Fund responded that it was their position that the technical advice memorandum referred only to the September 28, 1976, determinat…
  16. Treas. Reg. § 1.411(a)-6(d) — Year of service; hours of service; breaks in service.
    IRCRegulationsSep 9, 2016
    … for 1977 through 1989 is as follows: Year ending December 31 Hours of service completed 1977 1,000 1978 800 1979 1,000 1980 400 1981 1,000 1982 0 1983 400 1984 1,000 1985 0 1986 0 1987 500 1988 200 1989 1,000 Employee A's status as a participant during this period is determined as follows: 1978: Employee A was a plan …
  17. 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 .…
  18. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …0 12/01/1976 03/01/1977 7.00 03/01/1977 06/01/1977 7.00 06/01/1977 12/01/1977 6.75 12/01/1977 03/01/1978 6.75 03/01/1978 06/01/1978 7.00 06/01/1978 09/01/1978 7.25 09/01/1978 03/01/1979 7.25 03/01/1979 06/01/1979 7.50 06/01/1979 09/01/1979 7.50 09/01/1979 12/01/1979 7.75 12/01/1979 03/01/1980 8.50 03/01/1980 06/01/1980…
  19. 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))…
  20. 82 T.C. 941; 82 T.C. No. 71 — Benbow v. Commissioner
    IRCCourt RulingsJun 7, 1984
    …titioners as follows: Deficiency Year Income tax Excise tax Donald L. Benbow and Patricia J. Benbow 1978 $542.50 $130.20 Daniel W. Cass, Jr., and Barbara L. Cass 1978 $811.00 294.00 Daniel W. Cass, Jr. 1979 294.00 Earl R. Lueckel and Lois B. Lueckel 1978 6,722.11 1979 913.87 913.87 Frederic E. Saunders and Mary Alice S…