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 RulingsAug 25, 1997★ strong match
…ircuit decided Adler v. Commissioner
, 86 F.3d 378, which vacated
and remanded our decision in T.C. Memo. 1995-148. In Adler v.
Commissioner
, the Court of Appeals agreed that the phrase "on
account of" requires "a causal connection between the employee's
IRCCourt RulingsOct 29, 2002
… in 1989
when he had diplomatic status.
Petitioner claimed a $4,237 net operating loss (NOL) on his
1996 return. In a separate statement attached to his 1996
return, petitioner identified the NOL as a "net operating loss
carryover", but he did not state from which year or years he was
carrying the loss, Respondent sent…
IRCCourt RulingsDec 20, 2001★ strong match
hat they contend Ms. Whitehead performed for Burien Nissan during 1996, her compensation
for those services would have been $2,040, which is an amount substantially less than the value ($6,600) that petitioners
claimed in their 1996 joint return. Assuming arguendo that Ms.
Whitehead had worked 120 hours for Burien Niss…
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 RulingsJul 29, 2003
time he filed the petition in this case, petitioner’s
address was in Morton Grove, Illinois.
During 1996 and 1997, petitioner was engaged in a washing machine repair business from which he had net profit of
$30,200.31 and $30,227.02, respectively.
On April 18, 1996, respondent received from petitioner an
estimated tax …
IRCCourt RulingsFeb 9, 2023★ strong match
… 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 RulingsNov 7, 1996★ strong match
…ects 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)).
Accordingly, in order to give effect to our disposition of the
disputed issue, as well as respondent's concession, and to permit
- 16 -
12
See supra
no…
IRCCourt RulingsAug 8, 1996related by meaning
…iew 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 jurisdiction to abate
- 8 -
interest herein. See Commissioner v. McCoy
, 484 U.S. 3, 7
(1987); 508 Clinton Street Corp. v. Com…
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 RulingsJan 13, 2003
…tled
to alimony deductions in amounts greater than those conceded by
respondent for 1994, 1995, and 1996; (2) whether Mr. Meyer is
entitled to dependency exemptions for 1994, 1995, and 1996 for
his only child; (3) whether Mr. Meyer is entitled to a child care
credit for 1994, 1995, and 1996; (4) whether Mr. Meyer is li…
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 RulingsMay 15, 2006
ceived wage income of $1,076.
Petitioner had three IRAs during 1996,. one account with T.
Rowe Price (the T. Rowe Price IRA) and two accounts with the Lindner Growth Fund administered by Star Bank (the first Star
Bank IRA and the second Star Bank IRA, respectively). On
February 26, 1996, petitioner received a $7,000 di…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
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
4.25
04/01/1996
05/01/1996
4.75
05/01/1996
08/01/1996
5.00
08/01/1996
11/01/1996
5.25
11/01/1996
12/01/1996
5.00
12/01/1996
01/01/1997
4.75
01/01/1997
02/01/1997
4.50
02/01/1997
03/01/1997…
IRCCourt RulingsMay 22, 2002
… responded with instructions for the bank to
mail him a check for the minimum withdrawal amount. In 1996, petitioner mistakenly signed a form to close out
his IRA as of December 31, 1996. On December 31, 1996, Key Bank
closed petitioner’s IRA account and sent petitioner the entire
balance.
Petitioner reported his entir…
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 18, 1996★ strong match
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsNov 25, 2009related by meaning
…qualified retirement,plan . See secs . 4974(c)(1),
7701(j)(1) ; Dollander v . Commissioner , T .C . Memo . 2009-187 . It
is undisputed that petitioner's TSP distributions of $120,603
were early distributions made before she had attained the age of
59-1/2 years .
Imposition of the 10-percent additional tax is subject to…
IRCCourt RulingsSep 3, 1998
…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.…
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 …