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 …
Ann. 2015-19 — This announcement describes future changes to the determination letter program for qualified individually designed plans and sets forth an intended transition … IRCAnnouncementsAug 10, 2015related by meaning
… on or before October 1, 2015. Comments should be mailed to Internal Revenue Service, CC:PA:LPD:PR (Announcement 2015–19), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, D.C. 20044, or sent electronically to notice.comments@irscounsel.treas.gov. Please include “Announcement 2015–19” in the subject line of …
IRCCourt RulingsJul 19, 2007related by meaning
j
S M
'Q -" P " " ,
T .C . Summary Opinion 2007-122
UNITED STATES TAX COUR T
ANNA E . AND MARK S . WARRINGTON, Petitioners v .
COMMISSIONER OF INTERNAL REVENUE, Responden t
Docket No . 6035-06S . Filed July 19, 2007 .
Anna E . and Mark S . Warrington, pro sese .
Roland E . Collins, Jr . , for respondent .
RUWE, Judge :…
IRCPrivate Letter RulingsOct 8, 1999related by meaning
------------------------
--------------------------------------------------------------------------------------------------------------- ------------- ----------------------------------------------------------------------------------------------------------------------------
--------------------------------------------…
IRCCourt RulingsDec 30, 1998related by meaning
…30, 1998.
Held
: Under the facts of this case, direct
transfer of a portion of funds invested in an annuity
contract into another annuity contract qualifies as a
nontaxable exchange under sec. 1035, I.R.C. Other
issues also decided.
Dona Elizabeth Conway, pro se.
Blaine C. Holiday
, for respondent.
SWIFT, Judge
: Respo…
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 …
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 RulingsJun 24, 2003
…h Smith reported to the Internal Revenue Service (IRS) that Ms. Potter received $3,038 of income
in 1999. Petitioners did not report this amount as income on
either their 1999 Form 1040, U.S. Individual Income Tax Return,
or their 1999 Form 1040X, Amended U.S. Individual Income Tax
Return.
In March 1999, both Ian Potte…
Ann. 2005-33 — This document contains corrections to final regulations (T.D. 9166, 2005-8 I.R.B. 558) under section 9801 of the Code governing portability requirements for gr… IRCAnnouncementsMay 9, 2005related by meaning
…stration)
Internal Revenue Service
Department of the Treasury.
Dated this 16 th day of March, 2005.
Ann Agnew,
Executive Secretary,
Department of Health and Human Services.
Dated this 15 th day of February, 2005.
Daniel J. Maguire,
Director, Office of Health Plan Standards and Compliance Assistance,
Employee Benefits S…
IRCCourt RulingsMay 14, 2009
oners' 1999 Schedule
E shows that petitioners reported $22,980 of total rent received,
$29,457 of total expense deductions, and $7,318 of depreciation expenses, which resulted in rent and royalty losses of $13,796
._
for 1999
. Respondent's'computer printout of petitioners' 2001
Schedule E shows that petitioners did no…
IRCCourt RulingsAug 17, 1999related by meaning
T.C. Memo. 1999-275
UNITED STATES TAX COURT
FRANK A. SONIER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13527-98R. Filed August 17, 1999.
Frank A. Sonier, pro se.
Lawrence H. Ackerman
, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge
: This matter is before the Court
on responde…
PLR 200742010 — Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income) IRCPrivate Letter RulingsOct 19, 2007related by meaning
…r and subsequent submissions by Taxpayer
requesting ruling concerning the issuance of deferred gift annuities and the application
of section 72 of the Internal Revenue Code.
1
FACTS
Taxpayer represents that is a public charity within the meaning of section 509 of the
Internal Revenue Code and is exempt from tax under s…
IRCPrivate Letter RulingsMar 3, 2000
…SAR's immediately prior to the sale, at which time the SAR's would otherwise terminate.
On June 30, 1999, a change of control and recapitalization of X, resulted in X becoming a
C corporation. Thus, January 1, 1999 - June 29, 1999, constituted a short tax year for X
as an S corporation ("the S Short Year") and June 30,…
Ann. 2004-32 — Employee Plans determination letter program; individually designed plans. This announcement describes the Service’s decisions resulting from its review of comm… IRCAnnouncementsMay 3, 2004related by meaning
…re also invited to comment on the six-year amendment cycle for pre-approved plans described in this announcement.
Drafting Information The principal author of this announcement is James Flannery of the Employee Plans, Tax Exempt and Government Entities Division. For further information regarding this announcement, plea…
IRCCourt RulingsJan 30, 2007
…00 and $62,930, and the check for $27,000,
for total distributions of $589,930.
042 D. Petitioners' 1999 Federal Income Tax Return
Petitioners filed a joint Federal income tax return for 1999
on June 18, 2003.3 Petitioners reported adjusted gross income of
$564,156, itemized deductions of $427,211, a total tax of
$33,7…
IRCCourt RulingsJan 27, 1998related by meaning
1
All section references are to the Internal Revenue Code
in effect for the years at issue, unless otherwise indicated.
All Rule references are to the Tax Court Rules of Practice and
(continued...)
T.C. Memo. 1998-36
UNITED STATES TAX COURT
NEIL M. BAIZER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Doc…
IRCCourt RulingsOct 24, 2007
… an IRS stamp showing it was received by the IRS on May 30,
2000.
The joint return for taxable year 1999 shows a typed date of
“11-02-00” next to the signature of the paid return preparer.
- 12 -
The 1999 return also shows a typed date of “11-02-00” next to
both petitioner’s and Mr. Barrera’s signatures. The 1999 retur…
Notice 2009-86 — Further extension of effective date of normal retirement age regulations for governmental plans. This notice announces the intent to further extend the final e… IRCNoticesNov 16, 2009related by meaning
…n or modify the relief previously provided in Notice 2007-69, 2007-2 C.B. 468.
EXEMPT ORGANIZATIONS
Announcement 2009-80 Announcement 2009-80 The Service has revoked its determination that Elimidebt Management Systems, Inc., of Orlando, FL and Hallandale, FL; and Richard & Jane Pater Charitable Foundation of Salt Lake …
IRCCourt RulingsOct 20, 2003
… Ford
and moved to Georgia. Petitioner started construction on his
- 4 -
Georgia residence in March 1999. At some time in 1999,
petitioner transferred his ownership interest in the Michigan
residence to his former wife. Petitioner and his former wife
divorced in November 2002.
During 1999, petitioner withdrew $50,674 f…
IRCCourt RulingsSep 30, 2003
…l Income Tax Return, for the 1999 taxable year (1999 tax
return). They reported “Total pensions and annuities” of $27,880
and included $12,880 of that amount as part of their total income
for the 1999 taxable year. However, petitioners did not report
any additional tax under section 72(t)(1) with respect to the
$12,880…