Brief Case
Pension Resource

Search the Pension Law Library

Limit to:Advanced options
Searches the code/regs in effect on that date.
Words mode supports "quoted phrases", +required and -excluded terms.
Document types:
Go to T.C. Memo. 1997-126 (not yet in the library — opens the official source)
63 documents · 0.17sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 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…
  3. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  4. 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 …
  5. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001★ strong match
    …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…
  6. 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…
  7. 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 (…
  8. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    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…
  9. 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…
  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. T.C. Summary Opinion 2002-138 — Robert L. & Sara J. Helm v. Commissioner
    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…
  12. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    …cessitate suppression of evidence obtained after extension obtained); Epstein v. Commissioner, T.C. Memo. 1989-498 (failure to follow procedures set forth in Internal Revenue Manual did not invalidate statutory notice); First Federal Savings & Loan Association of Pittsburgh v. Goldman, 644 F. Supp. 101 (W.D. Pa. 1986) …
  13. 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 …
  14. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    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…
  15. T.C. Summary Opinion 2001-149 — Charles Frederick Held, Jr. v. Commissioner
    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…
  16. 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 …
  17. T.C. Memo. 2003-223 — Richard Wos v. Commissioner
    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…
  18. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  19. 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…
  20. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997related by meaning
    ct to the additions under section 6651(a), their failure to file tax returns was not due to reasonable cause; and, with respect to the additions under section 6654, they do not qualify for any exceptions to the additions in section 6654(e). The only remaining matters with respect to additions to tax are computational, …