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…
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★ strong match
one taxable year; at
best, petitioner's assertion undermines the characterization of
the 1992 distribution as a lump-sum distribution. That position, however, does not advance petitioner's case.
c. Frozen Deposit Rule
Finally, although it is not clear whether petitioner relies
on the special rule for frozen deposits f…
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 RulingsDec 19, 2000related by meaning
…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 of deficiency was not an
affected items notice of deficiency. Petitioners assert that t…
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 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…
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 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 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 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 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 RulingsOct 3, 1995related by meaning
…ion qualified for tax-free
rollover treatment under section 402(a)(5); Brown v.
Commissioner
, T.C. Memo. 1995-93 (same); cf. supra
with T.C. Memo. 1993-561.
- 13 -
10
It would appear that such stipulation would also affect
the amount of the excise tax under sec. 4980A. We leave this
matter to the parties as part of th…
IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
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 RulingsDec 11, 2003related by meaning
… T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, affd. 774
F.2d 426 (11th Cir. 1985).
3
See, e.g., Cavanaugh v. Commissioner
, T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir.
199…
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…