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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   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…
2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   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 …
3. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
   IRCCourt RulingsDec 20, 2001
   …y McLaughlin (Mr. McLaughlin) owned 24,000 shares of that stock (the McLaughlin shares). On May 25, 1990, Mr. Johnston, Jacque Johnston, and Mr. McLaughlin entered into a stock purchase agreement (May 25, 1990 stock purchase agreement) with Mr. Stanford, Mr. Whitehead, Patrick Watson (Mr. Watson), Gerald Buchner (Mr. B…
4. T.C. Memo. 2003-156 — Michael W. Duncan v. Commissioner
   IRCCourt RulingsMay 28, 2003
   …xaminations of petitioner and of Duncan & Associates with respect to their respective taxable years 1990 and 1991. On October 8, 1992, petitioner filed Federal income tax (tax) returns for his taxable years 1990 (1990 return) and 1991 (1991 return) after the respective due dates for such returns had passed. Petitioner …
5. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
   IRCCourt RulingsSep 18, 1996
   iency Determination For 1990 In the notice of deficiency for 1990, respondent determined that petitioners are liable for: (1) The additional tax under section 72(t) for a premature distribution from petitioner's IRA with First National, and (2) the excise tax under section 4980A for an excess distribution from such IRA…
6. T.C. Memo. 1998-145 — Estate of Hilda Ashman, Deceased; Phillip Ashman, Personal Representative v. Commissioner
   IRCCourt RulingsApr 22, 1998
   bution. We find that respondent reasonably relied on decedent's 1990 return, did not - 13 - challenge decedent's representations regarding the pension distribution, and allowed the period of limitations for 1990 to expire. (3) Decedent’s Change of Position or Representation for 1993 With respect to the third element re…
7. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
   IRCCourt RulingsApr 30, 1997
   …ge payments, ranging from 100 percent to just under 50 percent, as follows: Payment Due Date Feb.1, 1990 Apr.1, 1990 May 1, 1990 June 1, 1990 July 1, 1990 Aug.1, 1990 Total Payment $1,894.48 1,894.48 1,894.48 1,894.48 2,256.53 2,256.53 Payment By Petitioner $1,894.48 1,894.48 914.48 949.48 1,292.53 1,128.53 Petitioner'…
8. Treas. Reg. § 1.414(q)-1T(d) — Highly compensated employee (temporary).
   IRCRegulationsSep 9, 2016
   …refore, in determining the group of highly compensated employees for the April 1, 1989 to March 31, 1990 plan year, the determination year is the plan year ending March 31, 1990 and the look-back year is the plan year ending March 31, 1989. Example 2.Assume the same facts given above. With respect to the plan year begi…
9. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
   IRCCourt RulingsDec 11, 2003★ strong match
   … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
10. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    …wable itemized deductions. Respondent concedes that petitioners repaid unemployment compensation in 1990 in the amount of $1,715 and are entitled to rental depreciation of $2,889 for 1990. $5,952 and $6,471.50, and an accuracy-related penalty under section 6662(b)(1) for 1990 in the amount of $1,294.30. After concessio…
11. T.C. Memo. 1996-267 — G. Richard & Sara B. Childs v. Commissioner
    IRCCourt RulingsJun 11, 1996
    … in petitioner's Fidelity IRA was constructively withdrawn and received by petitioner on August 14, 1990. Petitioners' 1989 Return On their Federal income tax return (Form 1040) for 1989, filed August 15, 1990, petitioners included the taxable portion of the Transfer Refund in gross income. - 8 - 4 Petitioners also fil…
12. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    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 (…
13. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996★ strong match
    …etitioners are liable for an addition to tax under section 6651(a) for failure to timely file their 1990 income tax return. We hold that they are not. (3) Whether petitioners are liable for an accuracy-related penalty under section 6662(a) due to a substantial understatement of income tax. We hold that they are. FINDIN…
14. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996★ strong match
    … (1939). Respondent cites Tucker v. Commissioner , 69 T.C. 675 (1978), Kuntz v. Commissioner , T.C. Memo. 1992-650, and Kasey v. Commissioner , T.C. Memo. 1976-266, in support of her position. As discussed below, respondent's reliance on these cases is misplaced. In Tucker v. Commissioner , supra , the taxpayer was a t…
15. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
16. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    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))…
17. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    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…
18. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
19. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    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 …
20. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    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…