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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. 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…
6. 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…
7. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
   IRCCourt RulingsMar 6, 2001
   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…
8. 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 …
9. 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…
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. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …1992 through 1994 taxable years. The case at docket No. 9276-03 involves Ms. Zaklama's 1995 through 1997 taxable years. The remaining case involves Mr. Zaklama's 1995 through 1997 taxable years. We use the term "subject years" to refer collectively to Ms. Zaklama's 1992 through 1997 taxable years and to Mr. Zaklama's 1…
12. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    a tax professional. Cf. Streber v. Commissioner , 138 F.3d 216 (5th Cir. 1998), revg. T.C. Memo. 1995-601; Reser v. Commissioner , 112 F.3d 1258 (5th Cir. 1997), affg. in part and revg. in part and remanding T.C. Memo. 1995-572; Chamberlain v. Commissioner , 66 F.3d 729 (5th Cir. 1995), affg. in part revg. in part T.C.…
13. 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…
14. 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 …
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. 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.…
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. 1997-277 — Margaret M. Merker v. Commissioner
    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…
19. 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…
20. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007related by meaning
    … related to their investment in the partnerships; FPAAs were - 25 - 13 Bales v. Commissioner , T.C. Memo. 1989-568, involved deficiencies determined against various investors in several Hoyt partnerships. This Court found in favor of the investors on several issues, stating that “the transaction in issue should be resp…