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Go to T.C. Memo. 1991-462 (not yet in the library — opens the official source)
53 documents · 0.30sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  2. 120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 13, 2003
    …ocket Nos. 7620-98, 12136-98, Filed February 13, 2003. 19891-98, 7282-99, 12484-99. 1 For the years 1991-94, Ps made contr ibutions to a voluntary employee benefit trust (the postretirement medical trust) for the purpose of providing postretirement medical benefits to their employees. For 1991, Ps’ actuary computed the…
  3. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997
    …the Hickman corporation profit-sharing plan, sent respondent's Appeals Officer who was handling the 1991 audit a letter dated October 18, 1991, which set forth the final resolution of that audit (1991 settlement). The 1991 settlement provided, inter alia, that petitioner was to correct the alleged prohibitive [sic] tra…
  4. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
    IRCCourt RulingsJul 14, 2005related by meaning
    ll other agreements between the parties. The parties stipulate that neither of them has made any representations with respect to the subiect matter of this Agreement or any representations * * * except such representations as are specifically set forth herein and each of the parties hereto acknowledges that he or they …
  5. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    …________ 24,000.00 5,100.82 $29,100.82 Respondent computed the amount of the revised deficiency for 1991 by treating the principal amount of each of the loans that petitioner received in 1991 as a distribution of plan assets in 1991 (viz $3,827, as shown in the following schedule). In addition, respondent treated the a…
  6. T.C. Memo. 2003-156 — Michael W. Duncan v. Commissioner
    IRCCourt RulingsMay 28, 2003
    0 and 1991, respectively. At a time not disclosed by the record before September 1992, respondent commenced examinations of petitioner and of Duncan & Associates with respect to their respective taxable years 1990 and 1991. On October 8, 1992, petitioner filed Federal income tax (tax) returns for his taxable years 1990…
  7. 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))…
  8. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
  9. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996★ strong match
    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…
  10. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …t No. 2995-97 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1991 $169,437 — $33,887 1991 — — — 1992 71,110 $10,667 14,222 1993 93,111 — 18,622 Estate of Steven Sobo, Deceased, Bonnie Sobo, Executrix, and Bonnie Sobo, docket No. 2795-97 Addition to Tax Accuracy-Related Penalty Yea…
  11. 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.…
  12. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. SPALDING AND EVENFLO COMPANIES, INC.
    ERISACourt RulingsFeb 1, 1993
    h 13, 1991, attorney Richard B. Fellows responded on Respondent's behalf by letter to Joseph Roberts of DRC, referencing a telephone conversation with r. Roberts on March 13, 1991, and advising that steps were being taken to compile an accountant's report, and an attempt would be made to file these accountant's reports…
  13. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    T.C. Memo. 1999-80 UNITED STATES TAX COURT EDWARD CLASBY AND C.T. GARRAHAN INSURANCE AGENCY, INC., Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1616-97. Filed March 16, 1999. Paul F. Markham , for petitioners. Mark L. Hulse and Gary W. Bornholdt , for respondent. MEMORANDUM FINDINGS OF FACT A…
  14. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …0 09/01/1990 10/01/1990 7.25 10/01/1990 11/01/1990 7.50 11/01/1990 12/01/1990 7.75 12/01/1990 01/01/1991 7.50 01/01/1991 03/01/1991 7.25 03/01/1991 06/01/1991 7.00 06/01/1991 07/01/1991 6.75 07/01/1991 10/01/1991 7.00 10/01/1991 01/01/1992 6.75 01/01/1992 02/01/1992 6.50 02/01/1992 03/01/1992 6.25 03/01/1992 07/01/1992…
  15. 117 T.C. No. 19 — The Board of Trustees of the Sheet Metal Workers' National Pension Fund, In Its Capacity As Plan Administrator v. Commissioner
    IRCCourt RulingsDec 4, 2001
    l COLA Fund was amended to provide for a 1-percent cost-of-living benefit. In December 1991, the COLA Fund paid .96 percent as a COLA benefit, and the NPF Fund paid 2.04 percent. In March 1992, petitioner adopted a new article 8 that formally added the NPF COLA to the Plan, effective retroactively to January 1, 1991. I…
  16. 88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit
    IRCProposed Rules (FR)Proposed Nov 14, 2023
    ction 987 A. 1991 Proposed Regulations and Notice 2000-20 On September 25, 1991, the Treasury Department and the IRS published in the Federal Register proposed regulations under section 987 (56 FR 48457, September 25, 1991) (“1991 proposed regulations”). The 1991 proposed regulations provided that section 987 taxable i…
  17. 101 T.C. 489; 101 T.C. No. 32 — Powell v. Commissioner
    IRCCourt RulingsNov 29, 1993related by meaning
    aws. As to the precedential value of Memorandum Opinions, see, e.g., Newman v. Commissioner, 68 T.C. 494, 502 n.4 (1977). [Id. at 67; emphasis added.] In light of our restrained articulation in Darby, and particularly its caveat as to a community property situation, we are satisfied that Darby does not compel a decisio…
  18. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
  19. T.C. Memo. 1997-20 — Jerry L. Burton v. Commissioner
    IRCCourt RulingsJan 13, 1997
    …unts at Fluor Daniel, the "Retirement Plan" and the "Savings Investment Plan." Sometime in March of 1991, petitioner asked the plan administrator at Fluor Daniel to distribute to him the entire balance of each retirement account. By letters dated May 7 and May 13, 1991, the plan administrator acknowledged petitioner's …
  20. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    …ed agent of the Corporation. Burien Nissan experienced financial difficulties during 1990 and early 1991. On a date during 1991 not disclosed by the record, Mr. Stanford accepted an offer to manage a large automobile dealership in Hawaii. On September 13, 1991, Mr. Whitehead and Mr. Stanford entered into a stock purcha…