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Go to T.C. Memo. 1993-61 (not yet in the library — opens the official source)
58 documents · 0.29sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997
    nk of Harrah was an operating bank. On April 6, 1993, Harrah Bancshares, which owned approximately 96 percent of the stock of National Bank of Harrah, merged with Midwest Bancshares, and the common stock of Harrah Bancshares was canceled. On April 16, 1993, National Bank of Harrah merged with and into Midwest Bank, eac…
  2. T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner
    IRCCourt RulingsFeb 7, 2007related by meaning
    … related to their investment in the partnerships; FPAAs were - 25 - 13 Bales v. Commissioner , T.C. Memo. 1989-568, involved deficiencies determined against various investors in several Hoyt partnerships. This Court found in favor of the investors on several issues, stating that “the transaction in issue should be resp…
  3. T.C. Memo. 2011-56 — Delores Chenault v. Commissioner
    IRCCourt RulingsMar 9, 2011
    Illinois, and the City of Chicago, until her retirement in May 1993. At some time in or around 1993 petitioner applied for and was approved to receive monthly payments under two separate annuity contracts. First, petitioner applied to the Retirement Board (city board) of the Municipal Employees' Annuity and Benefit Fun…
  4. DOL Office of Administrative Law Judges — United States Department of Labor, Pension and Welfare Benefits Administration
    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…
  5. 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…
  6. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    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…
  7. T.C. Memo. 1998-164 — Roland R. & Virginia A. Fox v. Commissioner
    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 …
  8. 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…
  9. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    …ion qualified for tax-free rollover treatment under section 402(a)(5); Brown v. Commissioner , T.C. Memo. 1995-93 (same); cf. supra with T.C. Memo. 1993-561. - 13 - 10 It would appear that such stipulation would also affect the amount of the excise tax under sec. 4980A. We leave this matter to the parties as part of th…
  10. 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…
  11. T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (…
    IRCTreasury DecisionsMar 7, 2005related by meaning
    Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified. EXEMPT ORGANIZATIONS T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
  12. 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…
  13. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    et interest rate for the use of money shall be the higher of the rate on the date of the prohibited transaction or the rate on the date of correction. If a prohibited transaction is not corrected within the taxable period, disqualified persons participating in the prohibited transaction become liable for a second-tier …
  14. 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…
  15. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    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…
  16. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    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…
  17. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    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…
  18. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    …red by the Joint Committee on Taxation (the Blue Book); privatd letter rulings and technical advice memoranda issued after October 31, 1976; actions on decisions and general counsel memoranda issued after March 12, 1981 (as well as general counsel memoranda published in pre-1955 volumes of the Cumulative Bulletin); Int…
  19. T.C. Memo. 2001-146 — Michael T. Chappell v. Commissioner
    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 …
  20. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…