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Go to T.C. Memo. 1982-361 (not yet in the library — opens the official source)
67 documents · 0.50sAllIRCERISAPBGCJoint 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. T.C. Memo. 2000-266 — Lester L. & Susan P. Samford v. Commissioner
    IRCCourt RulingsAug 24, 2000
    …ing of documents required to be filed. All of the above documents were dated and notarized July 22, 1982. Even though these documents were notarized, petitioners claim, and respondent does not dispute, that these documents were actually executed after September 3, 1982. E. Transactions After September 3, 1982 In the St…
  3. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    eductions of Partnership Loss On their individual income tax return for 1982, the Bealors reported a loss of $80,915, representing their 3.252-percent share of MIT 82's partnership loss. James Cameron reported the same amount as his 3.252-percent share of those losses in his 1982 Federal income tax return. Frank Pettis…
  4. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997
    …til they were terminated on December 31, 1991, and January 31, 1992, respectively. - 4 - On June 4, 1982, petitioner borrowed $130,000 from the Hickman corporation profit-sharing plan (1982 plan loan). That loan, which was unsecured, was evidenced by a note payable to that plan and signed by petitioner (1982 note). The…
  5. 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 (…
  6. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000★ strong match
    …6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice of deficiency was not an affected items notice of deficiency. Petitioners assert that the period of limitation for assessment under TEFRA is inapplicable. We disagree with petitioners’ ar…
  7. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987★ strong match
    …rict of Columbia for the purpose of appointing independent counsel); 28 U.S.C. sec. 134(b) and (c) (1982) (duty to reside within district to which appointed and duty to reside near courthouse); 28 U.S.C. sec. 137 (1982) (division of duties among the judges of a district); 28 U.S.C. sec. 140(a) (1982) (power to adjourn …
  8. 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))…
  9. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    48 F.2d 306, 310 (9th Cir. 1945), affg. a Memorandum Opinion of this Court dated Jan. 5, 1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942). Generally, new issues may not be raised in a Rule 155 computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
  10. Ann. 2006-45 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsJul 31, 2006
    …ond James & Associates, Inc. 880 Carillon Parkway P.O. Box 12749 St. Petersburg, FL 33733-2749 4/26/1982 188. Raymond James & Associates, Inc. 880 Carillon Parkway P.O. Box 12749 St. Petersburg, FL 33733-2749 3/8/1982 189. RBC Dain Rauscher, Inc. Dain Rauscher Plaza 60 South Sixth Street Minneapolis, MN 55402-4422 3/2/…
  11. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999
    … from petitioner. Edgar Murray III (Murray) was a representative of Travelers. From January to June 1982, Murray and the pension committee met several times to discuss the program. Petitioner introduced - 6 - Player to Murray in the spring of 1982. Andrew Fantasia (Fantasia) was the certified public accountant for the …
  12. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …8/01/1981 10/01/1981 10.25 10/01/1981 11/01/1981 10.50 11/01/1981 12/01/1981 10.75 12/01/1981 01/01/1982 11.00 01/01/1982 02/01/1982 10.50 02/01/1982 03/01/1982 10.75 03/01/1982 06/01/1982 11.00 06/01/1982 08/01/1982 10.75 08/01/1982 10/01/1982 11.00 10/01/1982 11/01/1982 10.75 11/01/1982 12/01/1982 10.50 12/01/1982 01…
  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. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10066-93. Filed October 3, 1995. Harold L. Humberson, pro se. Alan R. Pere…
  15. Treas. Reg. § 1.410(a)-5(c)(3)(ii) — Year of service; break in service.
    IRCRegulationsSep 9, 2016
    …ng to nonvested participants). Thereafter, he does not complete a year of service. As of January 1, 1982, in computing his period of service under the plan his service prior to December 31, 1981, is not required to be taken into account for purposes of section 410(a)(1) and § 1.410 (a)-3. Example 2.The employee in exam…
  16. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
  17. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  18. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    …cy was correctly determined by the Commissioner. Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of the parties. Petitioners presented their revised trial mem…
  19. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
  20. Ann. 2005-59 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsSep 12, 2005
    …L 60603 3/11/1986 34. Burton J. Vincent, Chesley & Co. 105 West Adams Street Chicago, IL 60603 3/25/1982 35. Butler Wick & Co., Inc. City Center One Bldg. Youngstown, OH 44501 10/8/1992 36. BUYandHold Securities Corporation 110 Wall Street New York, NY 10005 10/5/2000 37. Carolina Securities Corp. 239 Fayetteville St. …