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78 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. 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 …
  2. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986
    …sed here. Estate of Rockwell v. Commissioner, 779 F.2d 931 (3d Cir. 1985), affg. on this issue T.C. Memo. 1984-674, 49 T.C.M. 331, 53 P-H Memo T.C. par. 84,674; Reed v. United States, 743 F.2d 481 (7th Cir. 1984); Fein v. United States, 730 F.2d 1211 (8th Cir. 1984); Estate of Ceppi v. Commissioner, 698 F.2d at 17; Fir…
  3. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-470 UNITED STATES TAX COURT HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10066-93. Filed October 3, 1995. Harold L. Humberson, pro se. Alan R. Pere…
  4. 85 T.C. 511; 85 T.C. No. 29 — Reinhardt v. Commissioner
    IRCCourt RulingsSep 30, 1985related by meaning
    nged position or newly stated position or from reclassifying certain individuals as employees for purposes of Federal income tax withholding. S. Rept. 95-1263 (1978), 1978-3 C.B. (Vol. 1) 315, 508. That narrow, specific relief provision for employers has nothing to do with the issue before the Court.
  5. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
  6. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …IT 85 and those advanced to MIT 85 was recorded as a prepayment of the compensation fee on Dec. 31, 1985, and is reflected in MIT 85's income for that year. Additionally, the payroll figure includes some $3,741 in interest. 23 Intercoastal/Machise filed an amended Form 1120 for the fiscal year ended June 30, 1986, in o…
  7. Treas. Reg. § 1.501(h)-2(d)(3) — Electing the expenditure test.
    IRCRegulationsJul 12, 2016
    …plans to voluntarily revoke its expenditure test election effective beginning with its taxable year 1985. X must file its notice of voluntary revocation on Form 5768 after December 31, 1983, and before January 1, 1985. If X files a notice of voluntary revocation on December 31, 1984, the revocation is effective beginni…
  8. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…
  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. 99 T.C. 379; 99 T.C. No. 21 — Citrus Valley Estates v. Commissioner
    IRCCourt RulingsSep 29, 1992
    Valley. King’s salary, on the accrual basis, from Citrus Valley for the years 1985 through 1988 was $67,400, $80,000, $87,200, and zero, respectively. In 1985, Citrus Valley adopted a defined benefit pension plan. King was the only participant in the plan during the years 1985 through 1988. On May 9, 1986, Citrus Valle…
  11. 88 T.C. 641; 88 T.C. No. 35 — Calfee, Halter, & Griswold v. Commissioner
    IRCCourt RulingsMar 23, 1987
    …tember 16, 1981. WSI adopted amendments to the plan on January 3, 1984, June 29, 1984, and July 23, 1985. WSI filed with respondent on March 14, 1984, a request for a determination that the plan, as amended, continued to qualify under section 401(a). Respondent issued a proposed adverse determination letter with respec…
  12. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
  13. Ann. 2004-72 — Nonbank trustees; section 1.408-2(e) of the regulations. This announcement contains a list of entities previously approved to act as nonbank trustees and nonba…
    IRCAnnouncementsOct 12, 2004
    …s, Inc. (Nationwide Financial Services, Inc.) One Nationwide Plaza Columbus, OH 43216 September 25, 1985 160. Nationwide Credit Union One Nationwide Plaza Columbus, OH 43216 April 13, 1978 161. NBC Securities, Inc. 1927 First Avenue North Birmingham, AL 35203 July 16, 1996 162. Neuberger & Berman 522 Fifth Ave. New Yor…
  14. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997
    …and Milo Chapman $25,000 plus 12 percent interest (collectively referred to as corporate loans). In 1985, Dura-Craft paid David Christie $10,000 on its $50,000 corporate loan, and Springbrook paid Milo Chapman $10,000 on its $25,000 corporate loan. At that time, Dura-Craft reduced its loan payable balance reflected in …
  15. T.C. Memo. 1999-161 — Roblene, Inc. v. Commissioner
    IRCCourt RulingsMay 13, 1999
    ted on August 9, 1985, and its principal business activity is real estate sales. It is the employer and plan administrator with respect to the ESOP, a defined contribution plan. Petitioner established the ESOP and the trust as of August 12, 1985, effective for plan years beginning on and after August 12, 1985. The plan…
  16. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997
    …arying amounts of Harrah Bancshares stock. In an attempt to repay the 1982 plan loan, on August 19, 1985, petitioner transferred to the Hickman corporation profitsharing plan 5,000 shares of Harrah Bancshares stock (Harrah Bancshares profit-sharing plan stock) and certain real property located in Oklahoma County, Oklah…
  17. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    oner , T .C . Memo . 2004-125 . - 6 - Petitioner has not argued, and she has failed to demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right . Consequently, we must uphold TRHCA section 408 if it bears a rational relationship to a legitimate govern…
  18. T.C. Memo. 1995-501 — James E. & Cynthia R. Copley v. Commissioner
    IRCCourt RulingsOct 17, 1995
    beginning in 1985, which was more than 3 years prior to the date on which the property was sold. Generally, sections 1001 and 61 require a taxpayer to recognize in the year of the sale gain realized on the sale of property. Section 1034, however, allows a taxpayer, in certain circumstances, to defer recognition of gain…
  19. 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…
  20. T.C. Memo. 2011-105 — Mark E. Warmoth v. Commissioner
    IRCCourt RulingsMay 19, 2011
    …. 274(d); sec. 1.274-5T(a), (c) (1), Temporary Income Tax Regs., 50 Fed. Reg. 46006, 46016 (Nov. 6, 1985). To meet the adequate records requirements of section 274(d), a taxpayer must maintain an account book, a log, or other documentary evidence which, in combination, is sufficient to - 57 - establish each element of …