IRCCourt RulingsJan 21, 1997
…ies of such judges are described in the Nebraska Constitution and Nebraska Revised Statutes.
During 1992, petitioner was a member of, and contributed to,
the Nebraska Retirement Fund for Judges (the fund). The fund was
established and is administered pursuant to Neb. Rev. Stat. secs.
24-701 through 24-714 (1995). It is…
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 RulingsMay 5, 1998
…t convinced us that they paid $100,000,
or any other amount, to a qualified welfare benefit fund in 1992.
Mr. Fox testified that he sent a certified cashier's check for
$15,000 to Employers Trust 2000. He testified that he sent
-16-
$22,500 in 1992 and $28,200 in 1993. There is no documentary
evidence to corroborate th…
IRCCourt RulingsDec 11, 2003related by meaning
… T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, affd. 774
F.2d 426 (11th Cir. 1985).
3
See, e.g., Cavanaugh v. Commissioner
, T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir.
199…
IRCCourt RulingsAug 6, 1997
…rs received self-employment income. We now address the
validity of each of these determinations. A. 1992 Tax Year
Respondent determined that during 1992 each petitioner
received income from IRA distributions, self-employment, and
interest, and that Mrs. Cujas received dividend income. These
determinations were based on…
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…
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 RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsJan 3, 2017★ strong match
…tory, creating no
legally enforceable rights for taxpayers. See, e.g., Greene v. Commissioner, T.C.
Memo. 1992-202, 1992 Tax Ct. Memo LEXIS 239; Tucker v. Commissioner, T.C.
Memo. 1983-210, 1983 Tax Ct. Memo LEXIS 578; Chapman v. Commissioner,
T.C. Memo. 1982-68, 1982 Tax Ct. Memo LEXIS 675; see also Marks v.
Commissio…
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 RulingsAug 1, 1996
Aetna and CNA
insurance companies.
During 1992, petitioner was participating in two retirement
plans offered by Northwestern Mutual Life Insurance Co. (Northwestern). One plan was a simplified employee pension (SEP)
plan for self-employed individuals qualified under section 408(b)
and (k); the other was a Keogh plan qu…
IRCCourt RulingsJun 17, 1996
…e. At the time the petition was filed,
petitioner's legal residence was Northport, New York. During 1992, petitioner earned $306.26 in taxable wages,
$299.36 in taxable interest, $106 for jury duty service, and
received $10,660 in unemployment compensation. Petitioner
properly reported all of this income on his 1992 Fe…
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 RulingsSep 25, 1996related by meaning
…er, docket No. 10897-93; and Frank A. Pettisani and
Lucille M. Pettisani, docket No. 23719-93.
T.C. Memo. 1996-435
UNITED STATES TAX COURT
BARRY B. BEALOR AND NANCY L. BEALOR, ET AL.,
1
Petitioners v
. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 13364-89, 14112-89, Filed September 25, 1996.
17236-89, 26434…
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 2, 1998
…mony
in the absence of corroborating evidence. See Niedringhaus v.
Commissioner
, 99 T.C. 202, 212 (1992). Thus, we hold that
petitioner did not use the two 1-acre lots and the airplane hangar
in a trade or business. Accordingly, we sustain respondent on this
issue.
Issue 6. Other Deductible Losses
The sixth issue is w…
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 RulingsJun 18, 1999related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
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 RulingsNov 25, 2009related by meaning
been working ever . since and I
continue to work ." -Petitioner's .contention, as best w e
-understand it, is that when she lost her membership in the Florida Air . National Guard, its personnel department . advised her
that she . . could, withdraw her TSP funds without penalty and
provided her "documentation" for this…