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 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 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 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 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 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 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
IRCCourt RulingsDec 19, 1995★ strong match
…fer Refund does not constitute a qualified total
distribution. See Wittstadt v. Commissioner
, T.C. Memo. 1995492; Humberson v. Commissioner
, T.C. Memo. 1995-470; Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 ; Adler v. Commissioner
, T.C.
Memo. 1995-148; Dorsey v. Commissioner
, T.C. Memo. 1995-97; Brown
v. Commissi…
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 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 (…
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 RulingsSep 3, 1998related by meaning
…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.…
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…
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 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…
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 …
IRCCourt RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
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…
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 …