IRCCourt RulingsMar 6, 2001★ strong match
…75), affd. without published opinion 552 F.2d 368
(5th Cir, 1977); Kiourtsis v. Commissioner
, T.C. Memo. 1996-534; Fitzpatrick v. Commissioner
, T.C. Memo. 1995-548. Even after she
received the no change letter, petitioner was aware that the 1992
tax year remained open. Petitioner signed three consents to
extend the t…
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);…
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…
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 …
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
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…
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 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 (…
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…
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 …
IRCCourt RulingsMar 1, 1999★ strong match
…nscript indicates that several payors issued information
returns to petitioner for the taxable year 1992 as follows:
Type of
Payor
Form
income
Amount
Geiger's Bvgs., Inc. 1099B S-T cap. gains $15,282
First Valley Bank 1099-INT Interest 34
U.S. Treasury Dept. 1099-INT Interest 16
Manufacturer's Life 1099R Taxable distr.…
IRCCourt RulingsMar 20, 1997related by meaning
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…
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…
IRCCourt RulingsJul 31, 2000★ strong match
…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…
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…
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…
IRCCourt RulingsJan 16, 2002related by meaning
…nial of
equitable relief under the last sentence of section 66(c). Beck
- 9 -
v. Commissioner, T.C. Memo 2001-198. Here, we review
respondent's denial of equitable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
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…
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…
IRCCourt RulingsOct 19, 2010related by meaning
… •
warnings that he was in danger of being penalized. For example,
in Mathews v. Commissioner, T.C. Memo. 2005-84, we told
petitioner:
"Even though the filing of the petition resulted in
respondent's concession of the sec. 72(t) additional tax,