IRCCourt RulingsJun 20, 2001
1995. We ruled that it
was then too late to raise that issue. Even if we had allowed
petitioner to raise the issue, he did not show he was entitled to deduct car and truck expenses for 1995. At trial, he testified
that he had a mileage log that showed that he used the truck 100
percent for business in 1995. However, he…
IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsAug 25, 1997★ strong match
…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 RulingsOct 11, 1995★ strong match
…ble for the 10-percent
additional tax imposed by section 72(t). See O'Connor v.
Commissioner
, T.C. Memo. 1994-170; Wheeler v. Commissioner
, T.C.
Memo. 1993-561; cf. Dorsey v. Commissioner
, T.C. Memo. 1995-97;
Brown v. Commissioner
, T.C. Memo. 1995-93.
III. Excise Tax Issues
Finally, we turn to respondent's excise t…
IRCCourt RulingsOct 3, 1995★ strong match
402(e)(1));
Hoppe v. Commissioner
, T.C. Memo. 1994-635 (same); Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 (same); see also Dorsey v.
Commissioner , T.C. Memo. 1995-97 (addressing whether a taxpayer
had received the "balance to the credit" in the context of
whether a Transfer Refund distribution qualified for tax-f…
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 RulingsJul 2, 2002
…
by the first deed of trust in favor of Great Western. The deed
was executed by David on August 11, 1995, and by Stephanie on August 21, 1995. The fair market value of the Atascadero
property was $207,500 at the time the deed was executed. The
outstanding balances on the loans from Great Western and
petitioner’s profit…
IRCCourt RulingsFeb 9, 2023related by meaning
… and June
30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon
Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M.
(CCH) 1707 (a case involving tax years 1979, 1980, and
1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d
825 (5th Cir. 1996)
In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
IRCCourt RulingsAug 30, 1999
…s unable to borrow against the
marital residence. The only funds available to petitioner in
January 1995 consisted of approximately $33,000 on deposit in two
IRA's that he maintained at BayBank. The foregoing financial
situation with respect to Mr. Czepiel did not change over the
period January 1995 through July 1995.
…
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 RulingsOct 3, 1995★ strong match
rred to and remained within the Pension System.
By choosing to transfer to the Pension System, * * *
[Taxpayer] opted * * * to receive a refund of his contributions and accumulated interest along with
reduced annuity payments in the future
. Thus, in
effect, Taxpayer elected to receive the "balance to the
credit" of hi…
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…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
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
07/01/1995
09/01/1995
4.75
09/01/1995
10/01/1995
5.00
10/01/1995
12/01/1995
4.75
12/01/1995
02/01/1996
4.50
02/01/1996
04/01/1996…
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 RulingsJan 31, 2001
…e, therefore, find that
Vanguard intended to name petitioner as recipient of the
Form 1099R.
During 1995, and in accordance with the supplemental final
judgment, petitioner paid Ms. Hodson $3,000 in cash.
By check dated December 21, 1995 (the check), Vanguard
Fiduciary Trust Co. (Vanguard) paid $23,192.18 to the order …
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 6, 2001
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 RulingsApr 12, 2000
itioner in taxable years 1995
and 1996 are includable in gross income. We hold they are. (3)
Whether individual retirement account (IRA) distributions received by petitioner in taxable years 1995 and 1996, as well as
pension and annuity distributions received by petitioner in
taxable year 1996, are includable in gross …
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 (…