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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …e 1992 notice of proposed rulemaking, dated January 30, 1992. 57 Fed. Reg. 3571 (Jan. 30, 1992). ● “1993 Temporary Income Tax Regulat ions (T.D. 8470; 58 FR 5263- 02), dated January 21, 1993.” Note that the stipulation here cites only Treasury Decision 8470, and fails to acknowledge the three later corrections to Treas…
2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005★ strong match
   er for calendar year 1993 except that the reference to "20% reduction" was changed to "50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA 1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this connection, prior to its amendment by OBRA …
3. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
   IRCCourt RulingsOct 3, 1995★ strong match
   … more equitable result. See Hildebrand v. Commissioner , 683 F.2d 57, 58 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Zadan v. Commissioner , T.C. Memo. 1993-85. After all, the power to legislate is exclusively the power of Congress and not of this Court or any other. See Iselin v. United States , 270 U.S. 245, 250 (1926…
4. 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…
5. T.C. Memo. 2000-100 — Ronna Joan Robertson v. Commissioner
   IRCCourt RulingsMar 24, 2000
   …ement accounts; and (3) whether petitioner is liable for additions to tax under section 6651(a) for 1993 and 1994 or under section 6654(a) for 1993. FINDINGS OF FACT 3 Petitioner resided at 318 Georgia Circle, Placentia, California, during the tax years at issue and at the time her petition was filed. Petitioner was bo…
6. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
   IRCCourt RulingsJun 18, 1999related by meaning
   …statutory interest imposed under section 6601. See Bax v. Commissioner , 13 F.3d 54, 56-57 (2d Cir. 1993), affg. an Order of this Court; LTV Corp. v. Commissioner , 64 T.C. 589, 597 (1975);
7. 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 …
8. 111 T.C. No. 12 — Robert C. & Nancy L. Arnold v. Commissioner
   IRCCourt RulingsSep 28, 1998
   r in the alternative, that the November 1993 distribution represented a cost-of-living adjustment. Held : P modified the series of substantially equal periodic payments by receiving the $6,776 from his IRA in November 1993 prior to the close of the 5-ye ar period beginning on the date of the first distribution in Decem…
9. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
   IRCCourt RulingsJun 3, 1998related by meaning
   …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 (…
10. 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))…
11. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …ion to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1992 $1,620 — $324 1993 6,262 — 1,252 John J. and Ophelia J. Mall, docket No. 1208-97 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1992 $6,186 — $1,237 1993 7,404 — 1,481 Lakewood Group Lakewood, do…
12. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997
    …rs and did not obtain any evidence linking petitioners to an income generating activity relating to 1993. Nevertheless, respondent proceeded to use BLS data to reconstruct petitioners' 1993 income. Therefore, respondent's determinations relating to petitioners' 1993 tax years are arbitrary, and respondent bears the bur…
13. T.C. Memo. 2003-12 — Richard J. Meyer, III v. Commissioner
    IRCCourt RulingsJan 13, 2003
    …Meyer gave birth to the couple’s only child Richard J. Meyer IV (Richard). Between February and May 1993, Mr. Meyer, Ms. Meyer, and Richard moved to Seattle, Washington. In May 1993, Mr. Meyer and Ms. Meyer separated. Mr. Meyer and Ms. Meyer did not enter into a formal separation agreement. After separating, Ms. Meyer …
14. 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…
15. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    …in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of T.C. Memo. 1996-265 UNITED STATES TAX COURT HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20303-94. Filed June 11, 1996. Janet I. McCurdy , for petitioners. Alan…
16. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …
17. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997
    nk of Harrah was an operating bank. On April 6, 1993, Harrah Bancshares, which owned approximately 96 percent of the stock of National Bank of Harrah, merged with Midwest Bancshares, and the common stock of Harrah Bancshares was canceled. On April 16, 1993, National Bank of Harrah merged with and into Midwest Bank, eac…
18. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…
19. T.C. Memo. 2011-56 — Delores Chenault v. Commissioner
    IRCCourt RulingsMar 9, 2011
    Illinois, and the City of Chicago, until her retirement in May 1993. At some time in or around 1993 petitioner applied for and was approved to receive monthly payments under two separate annuity contracts. First, petitioner applied to the Retirement Board (city board) of the Municipal Employees' Annuity and Benefit Fun…
20. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    IRCCourt RulingsSep 3, 1998related by meaning
    …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.…