IRCCourt RulingsOct 19, 2010related by meaning
… •
warnings that he was in danger of being penalized. For example,
in Mathews v. Commissioner, T.C. Memo. 2005-84, we told
petitioner:
"Even though the filing of the petition resulted in
respondent's concession of the sec. 72(t) additional tax,
IRCCourt RulingsJun 28, 2010related by meaning
…ent,inniaking See Green'v . Commissioner ,
507 F .3d 857, 868' (5th Cir . 2007)' - : affg' . T .C . Memo . 2005-250 ;-
10 -
Stocks v . Commissioner, 98 .T .C . 1,_ 9 4(1992) "[T]he critical
question is, in lieu of what was the settlement amount paid"?,
Bagley v . Commissioner , 105 T .C ._ 396, 406 (1995) . ., affd . -…
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 RulingsJun 11, 1996
… in petitioner's Fidelity IRA was constructively withdrawn
and received by petitioner on August 14, 1990.
Petitioners' 1989 Return
On their Federal income tax return (Form 1040) for 1989,
filed August 15, 1990, petitioners included the taxable portion
of the Transfer Refund in gross income.
- 8 -
4
Petitioners also fil…
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.…
IRCCourt RulingsJun 4, 1997
…made contributions of $89 and $139 on behalf of Mrs.
Lozon to the profit sharing fund for the years 1990 and 1991,
respectively.
Allstate also allowed petitioners to participate in its
pension plan. Allstate made contributions of $1,674 and $2,319
on behalf of Mr. Lozon into Allstate's pension plan for the years
- 7 -
…
IRCCourt RulingsDec 28, 2000
…ry 1, 1992, from the plan
as follows:
Date
Amount
Mar. 1, 1988 $62,000
Mar. 7, 1988 20,000
Apr. 16, 1990 10,000
Apr. 19, 1990 100,000
Apr. 20, 1990 6,000
Apr. 30, 1990 6,000
May 19, 1990 6,500
The plan allowed loans to participants but limited the amount of
any loan, required a Qualified Waiver of Spouse from the
parti…
IRCCourt RulingsJun 12, 1996
…etitioners are liable for an addition to tax
under section 6651(a) for failure to timely file their 1990 income tax return. We hold that they are not.
(3) Whether petitioners are liable for an accuracy-related
penalty under section 6662(a) due to a substantial understatement
of income tax. We hold that they are.
FINDIN…
IRCCourt RulingsOct 3, 1995
…ussion of the Retirement System and the Pension
System, see generally Hylton v. Commissioner
, T.C. Memo. 1995-27;
Hoppe v. Commissioner
, T.C. Memo. 1994-635; Hamilton v.
Commissioner
, T.C. Memo. 1994-633; Maryland State Teachers
Association v. Hughes
, 594 F. Supp. 1353, 1357-1358 (D. Md.
1984).
4
So stipulated.
IRCCourt RulingsMay 29, 1997related by meaning
…
prior years. Easter v. Commissioner
, 338 F.2d 968, 969-970 (4th
Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v.
Commissioner
, 55 T.C. 28, 32 (1970). We reject petitioners’
argument that an exception to this rule applies to disputes
involving $10,000 or less.
To reflect the foregoing,
Decision will be entere…
81 FR 43430 — Department of Labor Federal Civil Penalties Inflation Adjustment Act Catch-Up Adjustments ERISAFinal Rules (FR)Jul 1, 2016
…ay be established by regulation pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended)” and adding in its place “(such amounts to be adjusted for inflation pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended).”
§ 2560.502c-7
[Amended]
50. Amend § 2560.502c…
IRCPrivate Letter RulingsMar 3, 2000related by meaning
…C:EBEO:4
TL-N-4712-99
UILC: 419.00-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR
FROM: Assistant Chief Counsel (Employee Benefits and Exempt
Organizations) CC: EBEO
SUBJECT:
This Field Service Advice is in res ponse to your memorandum dated October 5,
1999. Field Service Advice is not …
IRCCourt RulingsJul 31, 2000related by meaning
red all of petitioners’
arguments for contrary holdings; those arguments not discussed
herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent
necessary to reject or sustain each determination . We also have
considered all of respondent’s arguments a…
IRCCourt RulingsJun 11, 1996related by meaning
g, we give effect to the
plain meaning of the words used therein and sustain respondent's
determination that petitioners are liable for the 10-percent additional tax under section 72(t).
We have considered petitioners' remaining arguments and find
them unpersuasive.
3. Conclusion
In order to give effect to our disposit…
IRCCourt RulingsJul 9, 1997
itted three returns for tax year 1990. Petitioners' tax
returns reported the following information:
- 3 -
Year Return Date Tax Withholding Overpayment 1987 5/11/95 $5,515 $7,208 $1,693
1988 5/13/95 5,366 10,328 4,952
1990 1/15/96 5,564 6,919 1,355
1990 2/26/96 6,709 6,919 210
1990 3/15/96 5,942 6,919 977
1991 5/15/95 2…
IRCCourt RulingsJun 25, 2012related by meaning
other grounds, and
remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206;
Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 -
II. Administrative Costs
The administrative costs at issue are costs that petitioner incurred from the .
time respondent issued the notice of deficiency up to the …
IRCCourt RulingsNov 5, 1999
…disposition of the Defined
Benefit Plan assets.
The Defined Benefit Plan ceased benefit accruals in 1990,
at which time all plan participants were 100 percent vested. The
Defined Benefit Plan terminated pursuant to a resolution of
petitioner's board of directors dated September 4, 1990, and
effective September 26, 1990…
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 .…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
IRCCourt RulingsJul 13, 2010related by meaning
all of the contentions and arguments of
the parties that are not discussed herein, and we conclude that
they are without merit, irrelevant, or moot . "Para . 6 of the petition filed by each petitioner admits
:
"According to Section 6673, this court may penalize Petitioner up
to $25,000 for failure to complete the admin…