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21. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CURRENT DEVELOPMENT CORPORATION
    ERISACourt RulingsFeb 22, 2000
    he years 1992 - 1996, but that only the years 1995 and 1996 were sent to the DOL because that is all that the settlement agreement called for. (T 145) Mr. Arneson confirmed that he (they) did not respond immediately to Mrs. Palaoro's letter of April 26, 1999. (T 148) In August, 1999, [just before the hearing] they sent…
22. T.C. Memo. 1998-164 — Roland R. & Virginia A. Fox v. Commissioner
    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…
23. 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…
24. 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 .…
25. T.C. Memo. 1999-59 — Robert J. Geiger v. Commissioner
    IRCCourt RulingsMar 1, 1999
    …nscript indicates that several payors issued information returns to petitioner for the taxable year 1992 as follows: Type of Payor Form income Amount Geiger's Bvgs., Inc. 1099B S-T cap. gains $15,282 First Valley Bank 1099-INT Interest 34 U.S. Treasury Dept. 1099-INT Interest 16 Manufacturer's Life 1099R Taxable distr.…
26. PLR 199934002 — Deferred Compensation
    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 …
27. 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…
28. T.C. Memo. 1996-354 — Brent Allan Pulliam v. Commissioner
    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…
29. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    …x pursuant to section 72(t) as determined by respondent. See Aronson v. Commissioner , 98 T.C. 283 (1992). - 5 - Issue 2. Section 6651(a) Addition to Tax for Delinquency The next issue for our decision is whether petitioners are liable for the addition to tax under section 6651 for failure to
30. T.C. Memo. 1996-278 — Donald G. Russell v. Commissioner
    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…
31. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980related by meaning
    …etermination letters shall have limited application * * * See also Vernaccini v. Commissioner, T.C. Memo. 1974-66. Some of the cited cases raise the question of the application of secs. 165(a) and 23(p), I.R.C. 1939, to a determination of the proper effective date of trust instruments adopted by accrual basis taxpayers…
32. T.C. Memo. 1998-388 — Robert B. Keenan v. Commissioner
    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…
33. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    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…
34. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
35. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    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…
36. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    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…
37. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    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…
38. T.C. Memo. 1997-15 — Mark J. Vorwald v. Commissioner
    IRCCourt RulingsJan 8, 1997
    …ion. Background Some of the facts have been stipulated, and they are so found. Petitioner filed his 1992 Federal income tax return on June 15, 1995. He was single as of the close of 1992 and resided in Buellton, California, at the time that the petition was filed. In 1986, petitioner opened an individual retirement acc…
39. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    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…
40. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998
    iency Sec. 4971(b) Deficiency Sec. 6651(a) 1991 $772 --- $193 1992 1,310 $12,604 327 1993 3,250 31,999 812 1994 3,042 53,624 --- 1995 5,362 53,624 804 The second notice determined Federal excise tax deficiencies pursuant to section 4975 and additions to tax pursuant to section 6651 for 1992-95 (the second deficiency no…