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 RulingsDec 11, 1997
…the Hickman corporation profit-sharing plan, sent
respondent's Appeals Officer who was handling the 1991 audit a
letter dated October 18, 1991, which set forth the final resolution of that audit (1991 settlement). The 1991 settlement
provided, inter alia, that petitioner was to correct
the alleged prohibitive [sic] tra…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…ocket Nos. 7620-98, 12136-98, Filed February 13, 2003.
19891-98, 7282-99,
12484-99.
1
For the years 1991-94, Ps made contr ibutions to a
voluntary employee benefit trust (the postretirement
medical trust) for the purpose of providing
postretirement medical benefits to their employees. For
1991, Ps’ actuary computed the…
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 RulingsJun 3, 1998★ strong match
…________
24,000.00 5,100.82 $29,100.82
Respondent computed the amount of the revised
deficiency for 1991 by treating the principal amount
of each of the loans that petitioner received in 1991
as a distribution of plan assets in 1991 (viz $3,827, as
shown in the following schedule). In addition, respondent
treated the a…
IRCCourt RulingsMay 28, 2003
0 and
1991, respectively.
At a time not disclosed by the record before September 1992,
respondent commenced examinations 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…
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 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 8, 1996★ strong match
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 RulingsJul 31, 2000
…t No. 2995-97
Addition to Tax
Accuracy-Related Penalty
Year
Deficiency
Sec. 6651(a)(1)
Sec. 6662(a)
1991 $169,437 — $33,887
1991 — — —
1992 71,110 $10,667 14,222
1993 93,111 — 18,622
Estate of Steven Sobo, Deceased, Bonnie Sobo, Executrix, and
Bonnie Sobo, docket No. 2795-97
Addition to Tax
Accuracy-Related Penalty
Yea…
IRCCourt RulingsSep 3, 1998★ strong match
…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.…
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
ction 987
A. 1991 Proposed Regulations and Notice 2000-20
On September 25, 1991, the Treasury Department and the IRS published in the
Federal Register proposed regulations under section 987 (56 FR 48457, September 25, 1991) (“1991 proposed regulations”). The 1991 proposed regulations provided that section 987 taxable i…
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…
117 T.C. No. 19 — The Board of Trustees of the Sheet Metal Workers' National Pension Fund, In Its Capacity As Plan Administrator v. Commissioner IRCCourt RulingsDec 4, 2001
l COLA Fund was amended
to provide for a 1-percent cost-of-living benefit. In December
1991, the COLA Fund paid .96 percent as a COLA benefit, and the NPF Fund paid 2.04 percent.
In March 1992, petitioner adopted a new article 8 that
formally added the NPF COLA to the Plan, effective retroactively
to January 1, 1991. I…
IRCCourt RulingsNov 29, 1993related by meaning
aws. As to the precedential value of Memorandum Opinions, see, e.g., Newman v. Commissioner, 68 T.C. 494, 502 n.4 (1977). [Id. at 67; emphasis added.] In light of our restrained articulation in Darby, and particularly its caveat as to a community property situation, we are satisfied that Darby does not compel a decisio…
IRCCourt RulingsJan 13, 1997
…unts at Fluor Daniel, the "Retirement Plan" and
the "Savings Investment Plan." Sometime in March of 1991,
petitioner asked the plan administrator at Fluor Daniel to
distribute to him the entire balance of each retirement account.
By letters dated May 7 and May 13, 1991, the plan administrator
acknowledged petitioner's …
IRCCourt RulingsJun 18, 1999related by meaning
1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard,…
IRCCourt RulingsDec 20, 2001
…ed agent of the Corporation.
Burien Nissan experienced financial difficulties during 1990
and early 1991. On a date during 1991 not disclosed by the
record, Mr. Stanford accepted an offer to manage a large automobile dealership in Hawaii. On September 13, 1991, Mr. Whitehead
and Mr. Stanford entered into a stock purcha…
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 .…
115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner IRCCourt RulingsNov 9, 2000
…tion 419A(c), for its qualified asset account, as defined in section 419A(a),
was $64,615,936
5
for 1991 and $84,192,933 for 1992. The foregoing account limits for 1991 and 1992 included $53,313,236 and
$71,602,395, respectively, attributable to a reserve for postretirement medical benefits.
The Trust filed Forms 990, …