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…
Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013related by meaning
the Code. Both sections 18 and 19 describe generally the effect of § 7805(b) relief.
Generally applied retroactively to modify or revoke prior TAM
.03 A holding that modifies or revokes a holding in a prior TAM is applied retroactively, with one exception. If the new holding is less favorable to the taxpayer than the e…
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
Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and … IRCRevenue ProceduresJan 2, 2014related by meaning
P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made.
When no copy is given to the taxpayer
.06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
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 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 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 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 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 …
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 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 RulingsApr 2, 2020related by meaning
.............................. 116
2. Events .......................................... 117
3. Analysis and holding............................... 118 X. Period 15: July 27, 2009, through August 9, 2010. . . . . . . . . . . . . 119
1. Introduction...................................... 119
2. Events ....................…
IRCCourt RulingsSep 3, 1998★ strong match
…ting with a fiscal year ending June 30 as its
taxable year.
Petitioner was incorporated on July 15, 1983, and its
principal business activity is insurance consulting. It is the
employer and plan administrator with respect to the ESOP, a
defined contribution plan. It established the ESOP and the trust
on September 6, 19…
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 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 10, 2006related by meaning
… 86,112 sets forth a defined set of
circumstances in which the Service may apply a technical advice memorandum (TAM)
that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer.
Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under
§ 7805(b) an Associate Chief Counsel, as…