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76 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    …America/Bradley partners' capital accounts decreased from a deficit of $996,674 at the beginning of 1987 to a deficit of $2,853,708 at the end of 1987. During 1987, Mr. Bach assigned his entire interest in - 4 - 4 Although the exact date that Mr. Bach assigned his interest in America/Bradley to Mr. Goldstein is not cle…
  2. 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…
  3. T.C. Memo. 1996-337 — Parker-Hannifin Corporation v. Commissioner
    IRCCourt RulingsJul 24, 1996
    June 30, 1987, for employees covered under a collective bargaining agreement were included in the $3,210,000 contribution for union medical benefits. Petitioner's 1987 contribution included $9,022,227 for incurred but unpaid medical, dental, and short-term disability benefits. Postretirement Benefits--Retirees Reserve…
  4. 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 …
  5. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …ks stamped with the signature of Andrew Bryen (Andrew Bryen physically signed three W & A checks in 1987). One of the employees paid with W & A checks was Loretta Wilcox, a secretary with Machise. She had been hired by Bucci in September 1980, after she had filled out a formal employment - 86 - application. She could n…
  6. Treas. Reg. § 1.419-1T(b3)(3) — Treatment of welfare benefit funds. (Temporary)
    IRCRegulationsSep 9, 2016
    …welfare benefit fund with a taxable year ending January 31. During its taxable year ending June 30, 1987, and on or before January 31, 1987, the employer contributes $250,000 to the fund, and during the remaining portion of its taxable year ending June 30, 1987, the employer contributes $200,000. The qualified direct c…
  7. T.C. Memo. 1998-64 — Reed Smith Shaw & McClay; William J. Smith, Tax Matters Partner v. Commissioner
    IRCCourt RulingsFeb 17, 1998
    or the period beginning March 28, 1987, and ending April 24, 1987, reports that on April 15, 1987, 4,000 shares of stock of Saztec International, Inc. (Saztec), were sold for $31,998 or $8 per share, and on April 23, 1987, another 500 shares of Saztec stock were sold for $3,973 or $8 per share. Saztec was publicly trad…
  8. 103 T.C. 216; 103 T.C. No. 14 — General Signal Corp. v. Commissioner
    IRCCourt RulingsAug 22, 1994
    , 1987, and 1988, which were included in the application, were as follows: 1986 1987 1988 Anticipated contribution $33,788,071 $39,519,000 $37,000,000 Investment income 1,084,333 1,264,000 1,184,000 Total projected income 34,872,404 40,783,000 38,184,000 Anticipated expenses 29,303,726 32,800,000 36,736,000 Projected s…
  9. 92 T.C. 376; 92 T.C. No. 24 — Foil v. Commissioner
    IRCCourt RulingsFeb 22, 1989related by meaning
    o any participant which exceed the limitations of section 415(b). Paragraph (1) of subsection (d) shall not apply for purposes of this subparagraph.”. (c) Effective Date. — The amendments made by this section shall apply to taxable years beginning after December 31, 1978. [Senate Amendment to H.R. 4961, July 23 (legisl…
  10. 105 T.C. No. 29 — John U. & Sylvia Fazi v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …olved C in 1986 and distributed all of the assets in the plan 1 trust to employees, including P, in 1987. We held in Fazi v. Commissioner , 102 T.C. 695 (1994) (Fazi I), that plan 1 was not qualified and its related trust was not exempt during 1985, 1986, and 1987. We also held that, except for amounts conceded by R, P…
  11. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997
    …lso stipulated an increase, pursuant to section 419A(f)(7), in the amount of $432,010. Petitioner's 1987 VEBA Trust Contribution Pursuant to an amendment to the VEBA Trust agreement on December 29, 1987, employee welfare benefits for collectively bargained employees ceased to be funded through the VEBA Trust and were t…
  12. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997★ strong match
    performed by anyone else. Discussion Petitioners bear the burden of establishing that respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a); Welch v. Helvering , 290 U.S. 111 (1933). Petitioners' briefs refer to several facts which were not included…
  13. 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 (…
  14. 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…
  15. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    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.…
  16. 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…
  17. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …0 05/01/1986 10/01/1986 7.75 10/01/1986 11/01/1986 7.50 11/01/1986 12/01/1986 7.75 12/01/1986 03/01/1987 7.50 03/01/1987 06/01/1987 7.25 06/01/1987 07/01/1987 7.50 07/01/1987 10/01/1987 7.75 10/01/1987 11/01/1987 8.00 11/01/1987 03/01/1988 8.25 03/01/1988 04/01/1988 8.00 04/01/1988 06/01/1988 7.75 06/01/1988 09/01/1988…
  18. 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…
  19. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997
    x 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6661(a) 1987 $7,348-367 1 - 1988 29,345 2,935 1,467-7,336 1 50 percent of the interest due on the deficiency. Unless otherwise indicated, all section and Code references are to the Internal Revenue Code as in effect for the years in issue, and all Rule references are to the Tax …
  20. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    Commissioner's determination for abuse of discretion. E2, Sego v. - 18 - [*18] Commissioner, 114 T.C. at 610. The Appeals Office abuses its discretion when its exercise of discretion is arbitrary, capricious, or without sound basis in fact or law. Murphy v. Commissioner, 125 T.C. 301, 308, 320 (2005), aff'd, 469 F.3d 2…