IRCCourt RulingsFeb 9, 2023★ strong match
year
On or before Apr. 21, 1993 1968 regulations, redesignated in 1993
After Apr. 21, 1993, and on o r
before Oct. 6, 1994
1993 temporary regulations The preamble to the 1994 final regulations contained a discussion
of the legislative history of the commensurate- with-income sentence
that had been added to section 482…
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…
IRCCourt RulingsJul 14, 2005★ strong match
er for calendar year
1993 except that the reference to "20% reduction" was changed to
"50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA
1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this
connection, prior to its amendment by OBRA …
IRCCourt RulingsJun 18, 1999related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
IRCCourt RulingsMar 24, 2000
…ement accounts; and (3)
whether petitioner is liable for additions to tax under section 6651(a) for 1993 and 1994 or under section 6654(a) for 1993.
FINDINGS OF FACT
3
Petitioner resided at 318 Georgia Circle, Placentia,
California, during the tax years at issue and at the time her
petition was filed. Petitioner was bo…
IRCCourt RulingsJul 31, 2000★ strong match
…ion 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 Group
Lakewood, do…
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 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 …
IRCCourt RulingsSep 28, 1998
r in the alternative, that the November 1993
distribution represented a cost-of-living adjustment.
Held
: P modified the series of substantially equal periodic payments by receiving the $6,776 from his IRA in
November 1993 prior to the close of the 5-ye ar period
beginning on the date of the first distribution in
Decem…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
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
5.75
02/01/1993
03/01/1993
5.50
03/01/1993
04/01/1993
5.25
04/01/1993
08/01/1993
5.00
08/01/1993
10/01/1993
4.75
10/01/1993
11/01/1993
4.25
11/01/1993
01/01/1994
4.25
01/01/1994
04/01/1994…
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 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 …
ERISACourt RulingsAug 14, 2026
t this statement “necessarily implies that pre-1993 ret irees had lifetime, uncapped
benefits.” Kaiser, 2024 WL 1283535, at *4. But, read closely, this was not an affirmative statement or argument made by Alcoa;
it was simply a summary of the opposing side’s position. Such
statements cannot trigger judicial estoppel.
Seco…
IRCCourt RulingsJun 3, 1998related by meaning
…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 (…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999★ strong match
ions to tax under section
6651(a)(2) and that the addition to tax under section 6651(a)(1)
for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax
under section 6651(a)(1), except as conceded by respondent.
Decision will be entered
under Rule 155
.
IRCCourt RulingsAug 6, 1997
…rs and did not obtain any evidence linking
petitioners to an income generating activity relating to 1993.
Nevertheless, respondent proceeded to use BLS data to reconstruct
petitioners' 1993 income. Therefore, respondent's determinations
relating to petitioners' 1993 tax years are arbitrary, and
respondent bears the bur…
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 RulingsJan 13, 2003
…Meyer gave birth to the couple’s only
child Richard J. Meyer IV (Richard).
Between February and May 1993, Mr. Meyer, Ms. Meyer, and
Richard moved to Seattle, Washington. In May 1993, Mr. Meyer and
Ms. Meyer separated. Mr. Meyer and Ms. Meyer did not enter into
a formal separation agreement.
After separating, Ms. Meyer …
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…