IRCCourt RulingsFeb 9, 2023★ strong match
… 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…
IRCCourt RulingsSep 25, 1996
…t to BBPA of professional fees of $14,366.
Tax Deductions
On their individual income tax return for 1983, the 25
participants in MIT 83 reported Schedule E partnership losses
from MIT 83 in proportion to their interests in the partnership.
Respondent issued a notice of final partnership
administrative adjustment to MIT…
IRCCourt RulingsJul 31, 1989
…find this to be a non sequitur. The admittedly proper partial rollover was recorded on September 8, 1983. The 60-day rollover period expired on September 12, 1983. The first monthly statement after these events was for the period ended September 30, 1983. If petitioner had failed to actually transfer the lump-sum distr…
IRCCourt RulingsSep 29, 1992
…Post-retirement interest 5% 5%
Salary scale 4% -0-
Pre-retirement turnover -0--0-
Mortality (males) 1983 IAM-4 1983 IAM-4
Mortality (females) 1983 IAM-10 1983 IAM-10
Form of benefit ,
For purposes of these calculations, Matthews used the following data for the Foxes:
Jonathan Fox Renee Fox
Date of birth 2/2/53 2/20/52
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,…
IRCCourt RulingsFeb 7, 1989
…the plans’ funding. No further withdrawals from the extra checking account were made until July 15, 1983, as described below. On April 20, 1983, petitioner applied for an extension of time in which to file the plans’ annual returns for the year in issue. Thereafter, acting on the consultants’ advice that the contributi…
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 (…
IRCCourt RulingsMar 20, 1997
…rook
were performed at the office of Dura-Craft by employees of DuraCraft.
A. Loans
On February 10, 1983, the Chapmans and the Christies each
requested a loan in the amount of $37,500 from the Dura-Craft
Profit-Sharing Plan (Plan) to meet unspecified "emergency
financial requirements". On February 22, 1983, the Chapman…
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…
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))…
IRCCourt RulingsAug 13, 1990★ strong match
…The Form 872 signed by petitioner Robert C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states:
IRCCourt RulingsMay 3, 1995
…r the taxable year 1987. The financial statements of the National Presto VEBA for the taxable years 1983, 1984, and 1985 state that, for those years, the VEBA did not have investment income because “the Plans fund benefits paid and expenses as incurred”. (Emphasis supplied.) At the close of each of the taxable years 19…
IRCCourt RulingsSep 3, 1998★ strong match
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…8/01/1982
10/01/1982
11.00
10/01/1982
11/01/1982
10.75
11/01/1982
12/01/1982
10.50
12/01/1982
01/01/1983
10.25
01/01/1983
02/01/1983
10.00
02/01/1983
04/01/1983
9.75
04/01/1983
06/01/1983
9.50
06/01/1983
09/01/1983
9.25
09/01/1983
02/01/1984
9.50
02/01/1984
03/01/1984
9.75
03/01/1984
04/01/1984
9.50
04/01/1984
05/01/19…
IRCRegulationsMay 18, 2016
…andard mortality table means one of the following tables: the UP-1984 Mortality Table (Unisex); the 1983 Group Annuity Mortality Table (1983 GAM) (Female); the 1983 Group Annuity Mortality Table (1983 GAM) (Male); the 1983 Individual Annuity Mortality Table (1983 IAM) (Female); the 1983 Individual Annuity Mortality Tab…
IRCCourt RulingsOct 12, 1978related by meaning
do not deal with the operations of the plan, there is a substantial, *60 immediate, and real controversy between parties with adverse legal interests. In summary, although we lack jurisdiction of most of the allegations in the petition since they relate either to operational matters or to matters not raised in the comm…
81 FR 47534 — Proposed Revision of Annual Information Return/Reports ERISAProposed Rules (FR)Proposed Jul 21, 2016
…ty
1
1971 Group Annuity Mortality (G.A.M.)
2
1971 Individual Annuity Mortality (I.A.M.)
3
UP-1984
4
1983 I.A.M
5
1983 G.A.M
6
1983 G.A.M. (solely per Rev. Rul. 95-28)
7
UP-1994
8
Mortality table applicable to current plan year under section 1.431(c)(6)-1 of the Income Tax Regulations
9
RP-2000
10
RP-2000 (with Blue Col…
IRCCourt RulingsAug 25, 1997related by meaning
…reply brief includes 4-½ pages of objections to respondent's
proposed findings of fact. Id
.
I. The Memorandum Opinion
In T.C. Memo. 1995-492, filed October 11, 1995, the Court
decided the present case. In our memorandum opinion, we rejected
petitioners' argument that petitioner's Transfer Refund had not
been received …
IRCCourt RulingsMay 11, 1998
…d is
irrelevant under the statutory scheme for taxation of such
benefits.
Section 86 was enacted in 1983. Social Security Amendments
of 1983, Pub. L. 98-21, sec. 121(a), 97 Stat. 80. This provision
- 3 -
reversed a longstanding practice of excluding Social Security
benefits from income. See S. Rept. 98-23, at 25 (1983)…
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 …