IRCCourt RulingsFeb 9, 2023★ strong match
lieved that
the executive branch should conduct a comprehensive study of the 1968
regulations, and that the executive branch should carefully consider whether the 1968 regulations should be modified “in any respect.” H.R.
Conf. Rept. No. 99-841 (Vol. II), at II - 638 , 1986- 3 C.B. (Vol. 4) at 638.
Petitioner has a con…
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 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 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 RulingsApr 26, 2005★ strong match
…ns and to fashion equitable
remedies tö resolve these controversies." Simmons v.
Commissioner, T.C. Memo. 1995-422; see also Stevens v. Commissioner, T.C. Memo. 1985-192; Wenzel v. Commissioner, T.C.
Memo. 1982-595, affd. 707 F.2d 694 (2d Cir. 1983). Rather, in a
declaratory judgment action under section 7476, we must …
IRCCourt RulingsMar 20, 1997★ strong match
…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 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…
T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers … IRCTreasury DecisionsSep 29, 2003related by meaning
rders) applies for transfers, distributions, and payments made after December 31, 2001.
Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
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 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 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…
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…
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.…
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 RulingsAug 13, 1990★ strong match
t 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: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
IRCCourt RulingsAug 4, 1983
…ies); Moore v. Commissioner, 71 T.C. 533 (1979) (retail grocery store); Black v. Commissioner, T.C. Memo. 1983-245 (sales of developed real estate); Pilkington v. Commissioner, T.C. Memo. 1983-111 (operation of lounge); Smith v. Commissioner, T.C. Memo. 1983-93 (paint contracting business); Nelson v. Commissioner, T.C.…
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…
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 RulingsFeb 22, 1989related by meaning
…t of 1982. See 127 Cong. Rec. S 15578-15579 (daily ed. Dec. 16, 1981); 97-929 (Conf.) at 27 (1982), 1983-1 C.B. 377, 382.