IRCCourt RulingsFeb 9, 2023★ strong match
sformed into sections-1A and-2A (26 C.F.R. secs.
1.482-1A, -2A (1994)) and made applicable for tax year s beginning on or
before April 21, 1993.
MM. T he 1993 notice of proposed rulemaking
On January 21, 1993, the same day it issued Treasury Decision
8470, the Treasury Department published a notice of proposed
rulemaki…
75 FR 71047 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCProposed Rules (FR)Proposed Nov 22, 2010
…refighters' Retirement Fund or District of Columbia Teachers' Retirement Fund on or before June 30, 1997.
§ 29.352
Refunded contributions. For any given pay period, employee contributions are considered to have been made before the freeze date if the pay date was on or before June 30, 1997. As a result, for calendar ye…
77 FR 64223 — Federal Benefit Payments Under Certain District of Columbia Retirement Plans IRCFinal Rules (FR)Oct 19, 2012
' Retirement Fund or District of Columbia Teachers' Retirement Fund on or before June 30, 1997.
( printed page 64228)
§ 29.352
Refunded contributions. For any given pay period, employee contributions are considered to have been made before the freeze date if the pay date was on or before June 30, 1997. As a result, for…
IRCCourt RulingsApr 2, 2024related by meaning
er, we note that March 20, 2020, is in fact the
60th day after January 20, 2020.
We further note that on February 10, 2023, FEMA and the Department of Homeland Security amended the “notices of major disaster declarations and related
determinations resulting from the . . . pandemic beginning on January 20, 2020.”
Major …
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 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 RulingsApr 2, 2020related by meaning
…
T.C. 85, 101 (2004); Keller v. Commissioner, 568 F.3d 710, 718 (9th Cir. 2009),
aff'g in part T.C. Memo. 2006-166, and aff'g in part, vacating in part decisions in
related cases. Goldberg resided in Illinois when he filed his petition. Therefore
our decision will not be appealable to the First, Eighth, or Ninth Circui…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026related by meaning
… ON DECISION
Subject: Mohamed K. Abdo and Fardowsa J. Farah v. Commissioner, 162 T.C. 148 (April 2, 2024) (reviewed by the court). Issue: Whether the originally enacted version of 26 U.S.C. § 7508A(d)1 provided for an automatic and mandatory 60-day postponement of certain tax-related deadlines for all taxpayers affecte…
IRCCourt RulingsOct 18, 2002
… final regulations, secs.
1.408A-1 through -9, applicable to taxable years beginning after
Dec. 31, 1997. See sec. 1.408A-9, Income Tax Regs.
I have the problem with considering that as income,
when it isn’t, considering it as a distribution, which
it isn’t * * *. Now you owe tax on your Social
Security benefits, becau…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…5
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
4.75
03/01/1997
04/01/1997
5.00
04/01/1997
05/01/1997
4.75
05/01/1997
06/01/1997
5.00
06/01/1997
08/01/1997
5.25
08/01/1997
09/01/1997
4.75
09/01/1997
10/01/1997…
IRCCourt RulingsJun 3, 1998★ strong match
a tax professional. Cf. Streber v.
Commissioner
, 138 F.3d 216 (5th Cir. 1998), revg. T.C.
Memo. 1995-601; Reser v. Commissioner
, 112 F.3d 1258 (5th Cir. 1997), affg. in part and revg. in part and remanding
T.C. Memo. 1995-572; Chamberlain v. Commissioner
, 66 F.3d
729 (5th Cir. 1995), affg. in part revg. in part T.C.…
IRCCourt RulingsOct 8, 2003
…n the
basis of a fiscal year ending July 31. (We refer to J.D.’s
- 4 - taxable years ended July 31, 1997 and 1998, as J.D.’s 1997 and
1998 taxable years, respectively.)
On its 1996 tax return, Clarkston deducted a professional
(management) fee of $30,000 for services rendered to it during
that year by J.D. J.D. include…
IRCCourt RulingsMar 6, 2001
…ommissioner
, 105 T.C. 396
(1995), affd. 121 F.3d 393 (8th Cir. 1997); Green v.
Commissioner
, T.C. Memo. 1998-274; Goeden v. Commissioner
, T.C.
Memo. 1998-18; Wise v. Commissioner
, T.C. Memo. 1998-4; Kroposki
- 13 -
v. Commissioner
, T.C. Memo. 1997-563; Moran v. Commissioner
, T.C.
Memo. 1997-412; Fredrickson v. Co…
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 24, 2001
g 1997, petitioner was
employed by McNeary Insurance Consulting (McNeary) from January
to mid-February. During his employment with McNeary, petitioner was covered under a qualified retirement plan. Petitioner
contributed $131.03 to the McNeary retirement plan in 1997.
After leaving McNeary, petitioner was employed by H…
IRCCourt RulingsJul 29, 2003
… for each of the years at issue from his washing machine repair business and his
pension income for 1997 are not subject to tax is frivolous and
groundless. On the record before us, we hold that petitioner’s
net profit for each of the years at issue from his washing
machine repair business is subject to tax. We further…
IRCCourt RulingsDec 20, 2001
…petitioners’ 1996 joint return, petitioners claimed,
- 23 -
16
Petitioners attached to petitioners’ 1997 joint return Form W-2 for 1997 for Mr. Whitehead (Mr. Whitehead’s 1997 Form W2). That form showed “BURIEN NISSAN ADMINISTRATION” as employer
and Mr. Whitehead as employee. Mr. Whitehead’s 1997 Form W-2
showed, inter…
IRCCourt RulingsSep 17, 2026related by meaning
…cuit. See I.R.C. § 7482(b)(1) (flush language) ; Berenblatt v.
Commissioner, 160 T.C. 534, 542 n.4 (2023).
I. Petitioner’s C laim for A ward
O n February 3, 2013, petitioner filed Form 211, Application for
IRCCourt RulingsAug 25, 1997related by meaning
… TBOR2 do not apply in the present case. Maggie Management Co.
v. Commissioner
, 108 T.C.
(June 11, 1997).
warranted under the circumstances then present. Petitioners then
filed their motion for costs, as well as their motion for entry
of decision.
11
II. Discussion
We apply section 7430 as amended by the Technical and…
IRCCourt RulingsNov 28, 2001
…e conceded that he is not entitled to the $27 deduction, having never claimed this deduction on his 1997 income
tax return in the first instance and having failed to address the
issue before, during, or after the trial.
Although petitioner’s 1997 income tax return reflects a
claimed deduction of $5,807 for a contributi…