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 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 -
…
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 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 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 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.
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 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 RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …
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 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…
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 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 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 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…
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…
IRCPrivate Letter RulingsAug 27, 1999related by meaning
…Number: 199934002
Release Date: 8/27/1999
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Taxpayer's Name:
Taxpayer's Address:
Taxpayer's Ident. No.:
Taxable Years at Issue:
Date of Conference:
Legend
:
Taxpayer =
Plan =
Trust Agreement =
ISSUES
:
(1) Whether, under the rules of section 461 of the …
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 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 12, 1997
…K-1 issued to
petitioner indicates that petitioner's share of partnership
liabilities at the end of 1990 was $69,756. Luther Thompson, a
partner at Heidelberg & Woodliff, testified that he could not
vouch for the accuracy of that figure because it was handwritten
and not typewritten like the remainder of the schedule. …