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21. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997related by meaning
    itioner can show that he comes within one of the exceptions of section 6654(e). Hudson v. Commissioner , 103 T.C. 90, 110 (1994), affd. without - 26 - published opinion 71 F.3d 877 (5th Cir. 1995). Petitioner bears the burden of proof on this issue, Baldwin v. Commissioner , 84 T.C. 859, 871 (1985), and the record cont…
22. T.C. Memo. 1996-545 — Creston Swaim v. Commissioner
    IRCCourt RulingsDec 17, 1996related by meaning
    …hows that one of the statutory exceptions applies. Niedringhaus v. Commissioner , 99 T.C. 202, 222 (1992); Grosshandler v. Commissioner , 75 T.C. 1, 20-21 (1980). Petitioner bears the burden to show qualification for such exception. Habersham-Bey v. Commissioner , 78 T.C. 304, 319320 (1982). Petitioner has not sustaine…
23. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …t No. 1201-97 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1992 $1,620 — $324 1993 6,262 — 1,252 John J. and Ophelia J. Mall, docket No. 1208-97 Addition to Tax Accuracy-Related Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1992 $6,186 — $1,237 1993 7,404 — 1,481 Lakewood…
24. 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…
25. 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…
26. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    s another matter, and we can appreciate why respondent focuses on it. However, we are - 23 - reminded that petitioner's position as a project engineer required that he be substantially mobile and physically fit in order to perform his duties. Further, the record clearly demonstrates that as of October 1989, petitioner …
27. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    …n and not as findings of fact in this case. See Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff’d , 17 F.3d 965 (7th Cir. 1994). Petitioner resided in Washington when he petitioned this Court. Absent stipulation to the contrary, appeal of this case would apparently lie to the U.S. Court of Appeals for th…
28. 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…
29. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    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…
30. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
31. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997related by meaning
    ct to the additions under section 6651(a), their failure to file tax returns was not due to reasonable cause; and, with respect to the additions under section 6654, they do not qualify for any exceptions to the additions in section 6654(e). The only remaining matters with respect to additions to tax are computational, …
32. 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.…
33. 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…
34. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    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…
35. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    …ension System, see Adler v. Commissioner , 86 F.3d 378 (4th Cir. 1996), vacating and remanding T.C. Memo. 1995-148; Maryland State Teachers Association v. Hughes , 594 F. Supp. 1353, 13571358 (D. Md. 1984). Economic and Employment Development in Cambridge, Maryland. 3 As a Maryland State employee, petitioner was a memb…
36. 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…
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. 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…
39. 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.…
40. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    a tax professional. Cf. Streber v. Commissioner , 138 F.3d 216 (5th Cir. 1998), revg. T.C. Memo. 1995-601; Reser v. Commissioner , 112 F.3d 1258 (5th Cir. 1997), affg. in part and revg. in part and remanding T.C. Memo. 1995-572; Chamberlain v. Commissioner , 66 F.3d 729 (5th Cir. 1995), affg. in part revg. in part T.C.…