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21. T.C. Memo. 1997-34 — Mark J. & Mary A. Fuhrman v. Commissioner
    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…
22. 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…
23. 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…
24. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    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.…
25. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1996-556 UNITED STATES TAX COURT ALFRED P. DUFFY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6723-93. Filed December 23, 1996. Alfred P. Duffy, pro se. Judith Wilkie , for respondent. ME…
26. 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…
27. 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.…
28. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    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…
29. 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 .…
30. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    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…
31. 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…
32. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
33. 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…
34. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    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,
35. 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…
36. 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…
37. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
38. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
39. 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…
40. 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…