IRCCourt RulingsFeb 9, 2023★ strong match
…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 by the Tax Re form…
IRCCourt RulingsJun 20, 2001
… the issues for decision are:
1. Whether petitioner’s proper filing status is head of household for 1994 and 1995, as petitioner contends, or married
filing separately, as respondent contends. We hold that it is
married filing separately.
2. Whether petitioner is entitled to the earned income
credit for 1995. We hold t…
IRCCourt RulingsJul 14, 2005related by meaning
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 RulingsJan 31, 2001
…d support and alimony.
Former Wife’s counsel did not call this motion up for
hearing until June 23, 1994, at which time the Court removed the freeze on certain assets and temporarily
made certain assets available to the parties for use to
sustain them on an interim basis [by an order filed on
July 1, 1994 (the July 1, …
IRCCourt RulingsDec 16, 1998related by meaning
xcise tax returns could have concluded that the relevant
transfer was not a prohibited transaction, or, if it was, that
it had been corrected earlier. We have carefully considered all remaining arguments made
by the parties for holdings contrary to those expressed herein,
and, to the extent not discussed above, find th…
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 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 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 …
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
01/01/1994
4.25
01/01/1994
04/01/1994
4.50
04/01/1994
05/01/1994
4.75
05/01/1994
07/01/1994
5.25
07/01/1994
08/01/1994
5.50
08/01/1994
09/01/1994
5.75 09/01/1994
11/01/1994
5.50
11/01/1994
12/01/1994
6.00
12/01/1994
01/01/1995
6.25
01/01/1995
04/01/1995
6.00
04/01/1995
05/01/1995
5.75
05/01/1995
07/01/1995
5.50
07/01/1…
IRCCourt RulingsMay 21, 1999
eceived from sales of
insurance in 1994; (3) whether petitioner failed to include $440
in income received from a retirement plan distribution in 1994; (4) whether petitioner is subject to a 10-percent tax on a
premature distribution from a retirement plan in 1994, as
provided under section 72(t); and (5) whether petiti…
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…
IRCCourt RulingsFeb 24, 2014
the plan. No other contributions
were made during the period under consideration.
On October 6, 1994, K.H. Co., Inc., began operating as K.H. Co. The members of K.H. Co. were Carol Tomb (also known as Carol Hoffman) and the
K.H. Co. Inc. employee stock ownership trust. Immediately before the operating
change Ms. Tomb …
IRCCourt RulingsJul 6, 1998
request form dated October
27, 1994, petitioner elected to receive payment of her entire
account balance in the form of Gillette common stock plus the cash value of any fractional shares of such stock. As of
September 30, 1994, the account had 15.1473 shares of ESOP stock
which were convertible into 302.946 shares of G…
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 RulingsOct 11, 1995★ strong match
T.C. Memo. 1995-492
UNITED STATES TAX COURT
GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7123-93. Filed October 11, 1995.
Robert G. Cassilly
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Jud…
IRCCourt RulingsMar 24, 2000
…gage
Interest Statement reporting the payment of $8,189.68 in deductible mortgage interest. For the 1994 taxable year,
Transworld Mortgage Corp. issued petitioner and Adrianna a Form
1098 Mortgage Interest Statement reporting the payment of
$7,386.58 in deductible mortgage interest.
After the trial, the record remained…
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 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…
IRCCourt RulingsDec 19, 1995
…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 RulingsJun 18, 1999related by meaning
the facts have been stipulated, and they are so
found. Petitioner resided in Omaha, Nebraska, at the time that
his petition was filed with the Court. For the year in issue, petitioner and his wife filed a joint
Federal income tax return reporting wage income, which was earned
by petitioner's wife, in the amount of $4,…