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78 documents · 0.52sAllIRCERISAPBGCJoint 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. 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…
  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. 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…
  6. 81 T.C. 91; 81 T.C. No. 8 — Van Kalker v. Commissioner
    IRCCourt RulingsAug 4, 1983
    …utory 30-percent limitation applies. As explained in note 7, supra, Congress, in the Revenue Act of 1978, amended section 1348, effective for taxable years beginning after December 31,1978, to remove this mechanical 30-percent limitation and to permit an allocation which reflects a balancing of the relative importance …
  7. 90 T.C. 862; 90 T.C. No. 58 — New York State Teamsters Conference Pension & Retirement Fund v. Commissioner
    IRCCourt RulingsMay 9, 1988★ strong match
    …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…
  8. 82 T.C. 869; 82 T.C. No. 67 — Winger's Dep't Store, Inc. v. Commissioner
    IRCCourt RulingsJun 4, 1984★ strong match
    …nd Richard J. Rose, secretary of petitioner (hereinafter referred to as Rose). On or about April 4, 1978, petitioner issued a check in the amount of $70,000 to the pension plan as its employer pension contribution for the 1977 year. This check was deposited into the pension plan checking account at Security Pacific Nat…
  9. 71 T.C. 824; 1 Employee Benefits Cas. (BNA) 2016 — Tamko Asphalt Products, Inc. v. Commissioner
    IRCCourt RulingsFeb 15, 1979★ strong match
    loyees, which have less generous plans or no plans at all, this would generally constitute an impermissable discrimination. * * * [Emphasis supplied.] We believe that a fair reading of section 414(b) would have alerted petitioner to the fact that such section requires, inter alia, that an affiliated group- comprised of…
  10. 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))…
  11. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992★ strong match
    …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 …
  12. 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…
  13. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    … years. Sec. 274(e)(5) was amended and redesignated sec. 274(e)(4) by sec. 1114(b)(6) of Pub. L. 99-514, 100 Stat. 2085, 2451, the Tax Reform Act of 1986, effective for taxable years beginning after Dec. 31, 1986. H. Rept. 1447 at 428, 87th Cong., 2d Sess. at 428 (1962), 1962-3 C.B. 405, 423; S. Rept. 1881, 87th Cong. …
  14. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986★ strong match
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
  15. 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…
  16. 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 (…
  17. 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…
  18. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  19. 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 …
  20. 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…