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Go to T.C. Memo. 1992-383 (not yet in the library — opens the official source)
69 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023★ strong match
    …. See § 1.482-2(d). Sec. 1.482-1(b)(1), Proposed Income Tax Regs., 57 Fed. Reg. 3578-3579 (Jan. 30, 1992). The 1992 proposed regulations also contained proposed replacements to the tran sfer-pricing rules applicable to intangible property in section 1.482-2(d) of the 1968 regulations. 33 Fed. Reg. 5852 (Apr. 16, 1968);…
  2. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    …Service. The second ground was that respondent had conducted a second investigation of petitioner’s 1992 return, without notifying her of the need thereof, in violation of section 7605(b). On June 16, 1997, the Chief, Examination Division, Laguna Niguel, California, mailed petitioner a letter stating, with regard to th…
  3. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997★ strong match
    ng bank at the end of 1992. Based on our examination of the entire record before us, we find that petitioners have failed to show that they acted with reasonable cause and in good faith, or that they otherwise exercised due care or made a reasonable attempt to comply with the Code, when they claimed the 1992 and 1993 d…
  4. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997
    loyment was terminated on January 20, 1992, petitioner was employed by Unisys Corporation (Unisys). Petitioner was a participant in the Unisys Savings Plan (the plan). The plan is an “I.R.C. § 401(k) plan”. On January 20, 1992, petitioner requested an immediate total distribution of his vested balance in the plan (the …
  5. 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 …
  6. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    …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 (…
  7. T.C. Memo. 1996-517 — Jeffery Allen Robinson v. Commissioner
    IRCCourt RulingsNov 25, 1996
    …e interest because he used the interest to pay the fee for an income tax course that he attended in 1992 sponsored by H & R Block. Section 61(a)(4) provides that gross income includes "interest". Petitioner presented no authority to support his position that he could offset his interest income by the cost of a tax cour…
  8. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …5 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 6.50 07/01/1992 08/01/1992 6.25 08/01/1992 09/01/1992 6.00 09/01/1992 12/01/1992 5.75 12/01/1992 01/01/1993 6.00 01/01/1993 02/01/1993…
  9. 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))…
  10. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
  11. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998
    rm is used in section 7873. The parties further agree that in 1992 all employees of the hatchery received, in addition to wages, the choice to have an extra $160 per month paid for their benefit either into a health plan or a retirement account. Employees could not receive the monthly additional $160 amount except by c…
  12. T.C. Memo. 1997-108 — Hugo Madioni & Susanne J. Nicolai v. Commissioner
    IRCCourt RulingsMar 3, 1997
    e eligible to participate in Varian's pension plan. On December 31, 1992, Mr. Nicolai had a balance of $377.60 to his credit in Varian's pension plan. Petitioner Susanne J. Nicolai was employed by Morton F. Plant Hospital in 1992. Mrs. Nicolai began working at the hospital in 1990 and terminated her employment during t…
  13. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    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…
  14. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …
  15. T.C. Memo. 1998-399 — Ronny H. & Charlotte A. Schmalzer v. Commissioner
    IRCCourt RulingsNov 10, 1998
    50 Jan. 5, 1990 50 Apr. 18, 1990 1,100 May 4, 1991 $1,400 May 22, 1991 2,000 In 1992, petitioner made the following withdrawals from the IRA account: Jan. 29, 1992 $1,000 Apr. 6, 1992 2,000 July 21, 1992 2,000 Dec. 7, 1992 1,100 Total 6,100 On December 31, 1992, there was a balance in the IRA account of $1,374.53. Pet…
  16. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    ec. 402(a), 96 Stat. 324, 648, but had to be determined in the Toans’ individual case. Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert that the addition to tax under section 6659 was an affected item - 7 - for 1982 and that the related notice …
  17. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …t No. 1201-97 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1992 $1,620 — $324 1993 6,262 — 1,252 John J. and Ophelia J. Mall, docket No. 1208-97 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1992 $6,186 — $1,237 1993 7,404 — 1,481 Lakewood…
  18. 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…
  19. T.C. Memo. 1997-34 — Mark J. & Mary A. Fuhrman v. Commissioner
    IRCCourt RulingsJan 21, 1997
    …ies of such judges are described in the Nebraska Constitution and Nebraska Revised Statutes. During 1992, petitioner was a member of, and contributed to, the Nebraska Retirement Fund for Judges (the fund). The fund was established and is administered pursuant to Neb. Rev. Stat. secs. 24-701 through 24-714 (1995). It is…
  20. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CURRENT DEVELOPMENT CORPORATION
    ERISACourt RulingsFeb 22, 2000
    he years 1992 - 1996, but that only the years 1995 and 1996 were sent to the DOL because that is all that the settlement agreement called for. (T 145) Mr. Arneson confirmed that he (they) did not respond immediately to Mrs. Palaoro's letter of April 26, 1999. (T 148) In August, 1999, [just before the hearing] they sent…