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…
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…
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 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…
IRCCourt RulingsOct 11, 1995related by meaning
T.C. Memo. 1995-492
UNITED STATES TAX COURT
GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7123-93. Filed October 11, 1995.
Robert G. Cassilly
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Jud…
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 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.…
IRCCourt RulingsJun 11, 1996related by meaning
…in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20303-94. Filed June 11, 1996.
Janet I. McCurdy
, for petitioners.
Alan…
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…
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 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,…
IRCCourt RulingsFeb 22, 1989related by meaning
o any participant which exceed the limitations of section 415(b).
Paragraph (1) of subsection (d) shall not apply for purposes of this subparagraph.”. (c) Effective Date. — The amendments made by this section shall apply to taxable years beginning after December 31, 1978.
[Senate Amendment to H.R. 4961, July 23 (legisl…
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 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
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 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 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 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 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…