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 RulingsNov 21, 2007
… distributions from his IRA in the
aggregate amount of $331,500, as follows : Date Amoun t
Jan . 4, 1999 $70,00 0
Jan . 4, 1999 20,00 0
Feb . 1, 1999 15,00 0
Apr . 26, 1999 30,000
-11May 13, 1999 30,00 0
May 31, 1999 15,00 0
July 19, 1999 20,00 0
July 19, 1999 50,00 0
Sept . 20, 1999 10,00 0
Oct . 18, 1999 20,00 0
Oct …
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…
IRCCourt RulingsApr 11, 2012★ strong match
…red by the Joint
Committee on Taxation (the Blue Book); privatd letter rulings and
technical advice memoranda issued after October 31, 1976; actions on
decisions and general counsel memoranda issued after March 12,
1981 (as well as general counsel memoranda published in pre-1955
volumes of the Cumulative Bulletin); Int…
IRCCourt RulingsJun 9, 2005
…medical treatment received by petitioner and/or
petitioner’s family members during the taxable year 1999.
Exhibits 3-J, 4-J, and 5-J consisted of documents reflecting the
medical expenses which respondent conceded, along with the health
insurance premiums in the aggregate amount of $1,390 paid by
petitioner during taxa…
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 RulingsMar 31, 2005
siness trips made in taxable year 1999. As to her other
business expenses, petitioner does not know how these expenses
and deductions were calculated. Petitioner was disabled and unable to work from February to
June 1999. While on disability, petitioner spent no time on her
jewelry activity, the Port of Mystery. During…
Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par… IRCRevenue ProceduresModified Aug 2, 2021
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 Earnings, including the $575 for 1999 Earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 Earnings, including the $575 for 1999 Earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 Earnings, including the $575 for 1999 Earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
Rev. Proc. 2008-50 — This procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sectio… IRCRevenue ProceduresSep 2, 2008
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 earnings, including the $575 for 1999 earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
Rev. Proc. 2006-27 — Administrative programs; correction programs. This procedure updates and expands upon the Service’s comprehensive Employee Plans Compliance Resolution System (… IRCRevenue ProceduresSuperseded May 30, 2006
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 earnings, including the $575 for 1999 earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
IRCCourt RulingsSep 24, 2007
…01 and were divorced in 2002 .
Petitioner first learned that there were proposed
adjustments to the 1999 tax return when respondent offset a claimed overpayment from her 2001 tax return against a tax
balance due from 1999 .1 The amount remaining unpaid for 1999 a s
of March 2005 was $1,582 .58 .
Petitioner timely reque…
IRCCourt RulingsApr 14, 2005
ee Pension, Deduction on
the 1999 Return, Notice of Deficiency, and Tax Court
Proceedings
On March 10, 2000, petitioner made an $8,638 contribution to her simplified employee pension for 1999. Petitioner calculated
the contribution on the basis of the income she earned under the
personal service contracts.
- 13 -
Petit…
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 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…
IRCCourt RulingsFeb 18, 2004
ial goals, petitioner formed
Anthony Sadberry Family Trust No. 1 (the Trust) in 1999 to
finance Andrea's education and provide for her in the event of his death or incapacity. The Trust was assigned its own tax
identification number in March 1999 and was funded in part by the
net proceeds of the SFB distributions.9 In …
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 (…
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…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
e ,
dividend income, and interest income for t ax years 1999
through 2004 in the following amounts :
1999 2000 2001 2002 2003 2004
Net business
income $185,430 $121,207 $459,898 $502,412 $194,351 $153,593
Dividend
income
30 46 62 200 200 200
Interest
income
465 13,610 2,479 1,055 757 988
2. Whether p etitioners failed …