ERISACourt RulingsJun 9, 2000
…tained any assets. (J-23). These changes were made and submitted as a draft to the PWBA on June 22, 1993. The
draft was not signed. (J-24). An executed copy was submitted on
July 13, 1993. (J-25).
II. Procedural History
After the Regional Administrator issued the
Notice of Assessment on November 24, 1992, assessing a t…
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 RulingsMay 5, 1998
…rmination that petitioners
Roland and Virginia Fox received $2,237 in unreported interest
income in 1993 was arbitrary. We hold that it was.
-35. Whether petitioners Roland and Virginia Fox are liable
for self-employment tax of $10,658 for 1992 and $11,057 for 1993.
We hold that they are.
6. Whether petitioners Roland …
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
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 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…
T.D. 9310 — Final regulations under section 412(l)(7) of the Code provide mortality tables to be used in determining current liability for purposes of applying certain pen… IRCTreasury DecisionsFeb 26, 2007related by meaning
tal wages. The regulations apply to all employers and others making supplemental wage payments to employees.
Announcement 2007-22 Announcement 2007-22 This document contains corrections to final regulations (T.D. 9263, 2006-25 I.R.B. 1063) relating to the deductions for income attributable to domestic production activi…
T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua… IRCTreasury DecisionsMar 7, 2016related by meaning
or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security.
T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
IRCCourt RulingsDec 19, 1995
…fer Refund does not constitute a qualified total
distribution. See Wittstadt v. Commissioner
, T.C. Memo. 1995492; Humberson v. Commissioner
, T.C. Memo. 1995-470; Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 ; Adler v. Commissioner
, T.C.
Memo. 1995-148; Dorsey v. Commissioner
, T.C. Memo. 1995-97; Brown
v. Commissi…
IRCCourt RulingsDec 11, 2003
… 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 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 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 20, 2001
…Mrs. Chappell’s house).
D. Petitioner’s Workers’ Compensation Petitioner worked for Unisys Corp. in 1993, 1994, and for
part of 1995. He was injured on the job in January 1993, and
received weekly workers’ compensation of $400 from January 1993
to June or July 1995. He settled his workers’ compensation claim
on August …
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…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999
for the 5-percent excise
tax on prohibited transactions under section 4975(a) for 1982 to
1993.
2. Whether petitioners are liable for additions to tax under section 6651(a)(1) for 1982 to 1993. We hold that they are
to the extent discussed below.
At trial, respondent conceded that petitioners are not
liable for the 100…
T.D. 9331 — Final regulations amend section 408(a) of the Code with regard to the requirements under section 408(a) for non-bank trustees for deemed IRAs. The regulations … IRCTreasury DecisionsAug 6, 2007related by meaning
he Service anticipate issuing and requests comments on the issues intended to be addressed by such guidance.
Announcement 2007-68 Announcement 2007-68 This document contains numerous corrections to the preamble of final regulations (T.D. 9321, 2007-19 I.R.B. 1123) setting forth guidance on the application of section 40…
IRCCourt RulingsJan 31, 1973related by meaning
for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
IRCCourt RulingsJan 16, 2002related by meaning
…nial of
equitable relief under the last sentence of section 66(c). Beck
- 9 -
v. Commissioner, T.C. Memo 2001-198. Here, we review
respondent's denial of equitable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
IRCCourt RulingsOct 3, 1995
… more equitable result. See Hildebrand v. Commissioner
, 683 F.2d 57, 58 (3d Cir. 1982), affg. T.C. Memo.
1980-532; Zadan v. Commissioner
, T.C. Memo. 1993-85. After all,
the power to legislate is exclusively the power of Congress and
not of this Court or any other. See Iselin v. United States
, 270
U.S. 245, 250 (1926…
IRCRegulationsMay 18, 2016
…6-464, 1976-2 C.B. 115, with respect to all years credited under the stated benefit formula through 1993. The plan provides a stated benefit equal to 40 percent of compensation, payable annually as a straight life annuity beginning at normal retirement age. Normal retirement age under the plan is 65. The stated interes…