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…
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 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 RulingsNov 7, 1996related by meaning
…ner 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
notes 5, 7.
the parties to address the minor…
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 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 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 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…
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 …
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 …
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 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…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
T.C. Memo. 1999-80
UNITED STATES TAX COURT
EDWARD CLASBY AND C.T. GARRAHAN INSURANCE AGENCY, INC.,
Petitioners v
. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1616-97. Filed March 16, 1999.
Paul F. Markham
, for petitioners.
Mark L. Hulse
and Gary W. Bornholdt
, for respondent.
MEMORANDUM FINDINGS OF FACT A…
IRCCourt RulingsJan 12, 1998related by meaning
the deduction would frustrate a sharply defined
Federal or State policy. Wood v. United States
, 863 F.2d 417
(5th Cir. 1989); Fuller v. Commissioner , 213 F.2d 102 (10th Cir.
1954), affg. 20 T.C. 308 (1953); Holmes Enterprises v.
Commissioner
, 69 T.C. 114 (1977). The test of nondeductibility
is the severity and imme…
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 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 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…