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… in petitioner's Fidelity IRA was constructively withdrawn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 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 …
IRCCourt RulingsJul 9, 1997★ strong match
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 RulingsFeb 12, 2003related by meaning
d caselaw require
that corrective actions must be taken to requalify a plan that
has violated section 415. Martin Fireproofing v. Commissioner
,
supra at 1184; sec. 1.415-6(b)(6), Income Tax Regs.
Petitioners provided calculations to establish that the plan
was qualified as of the taxable year ending June 30, 1987. In
…
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 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…
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 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 .…
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…
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…
IRCCourt RulingsApr 14, 2005★ strong match
gard to any burden-shifting rule. See
Williams v. Commissioner
, 123 T.C. 144 (2004).
Background
This case was submitted to the Court fully stipulated pursuant to Rule 122. Petitioner resided in Berwyn Heights,
Maryland, when she filed her petition in this case.
A. Service Provided to the State Department Pursuant to
P…
IRCCourt RulingsMay 15, 1978related by meaning
…ards provisions of ERISA. 29 Fed. Reg. 56462 (1976).
Ets-Hokin & Galvan, Inc. v. Commissioner, T.C. Memo. 1962-136.
The term “period of severance” is defined under sec. 2530.200b-9(a)(3)(v) as follows:
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 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 RulingsJan 16, 2002related by meaning
…nial of
equitable relief under the last sentence of section 66(c). Beck
- 9 -
v. Commissioner, T.C. Memo 2001-198. Here, we review
respondent's denial of equitable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner IRCCourt RulingsNov 14, 1995
…1984 420,070 420,070
1985 388,300 388,300
1986 76,248 76,248
1987 105,900 105,900
1988 0 0
1989 0 0
1990 5,000,002 5,000,002
1991 0 0
1
Short period due to change in fiscal year.
In addition, in 1990, BI transferred improved real estate having
a value of approximately $2,700,000 to GSI as a dividend.
Dividend payments …
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…
IRCCourt RulingsJun 28, 2010related by meaning
a reasonable .dispute
with respect to any item of income reported on an information
return filed with the Secretary by a third party
:and the taxpayer has "fully cooperated with the Secretary (including providing,,-,
within ,a reasonable period-of time, access to and inspection of,
all witnesses, information, and docum…