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21. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    other grounds, and remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206; Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 - II. Administrative Costs The administrative costs at issue are costs that petitioner incurred from the . time respondent issued the notice of deficiency up to the …
22. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    … 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 the Ninth Circuit. See § 7482(b)( 1)(A)…
23. 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…
24. 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…
25. T.C. Memo. 2003-12 — Richard J. Meyer, III v. Commissioner
    IRCCourt RulingsJan 13, 2003
    …. Meyer) is entitled to alimony deductions in amounts greater than those conceded by respondent for 1994, 1995, and 1996; (2) whether Mr. Meyer is entitled to dependency exemptions for 1994, 1995, and 1996 for his only child; (3) whether Mr. Meyer is entitled to a child care credit for 1994, 1995, and 1996; (4) whether…
26. T.C. Memo. 2000-219 — Stephen R. Jones v. Commissioner
    IRCCourt RulingsJul 20, 2000
    old at the time of the distribution. On or before June 12, 1994, petitioner endorsed the Prudential check over to Ms. Jones. Ms. Jones did not deposit the IRA distribution check into an IRA or an Individual Retirement Account. On June 14, 1994, petitioner and Ms. Jones executed a 16page Stipulation for Judgment and Mar…
27. 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…
28. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    on. 2. Events Goldberg's 1994 return had been examined. We do not know if the 1994 examination occurred concurrently with the Goldbergs' 2003 and 2004 examinations, and we do not know if the 1994 examination occurred during Period 17. Buffamonte supervised the revenue agent who examined Goldberg's 1994 return. During t…
29. Treas. Reg. § 1.401(a)(4)-3(b)(6)(xi)(F) — Nondiscrimination in amount of employer-provided benefits under a defined benefit plan.
    IRCRegulationsMay 18, 2016
    …year of service after 1993, while retaining the one-percent formula for all years of service before 1994. Thus, the plan's amended benefit formula provides a benefit equal to the sum of the benefits determined under two benefit formulas: 0.75 percent of average annual compensation per year of service, plus 0.25 percent…
30. 93 T.C. 736; 93 T.C. No. 59 — Brown v. Commissioner
    IRCCourt RulingsDec 19, 1989related by meaning
    …cy was correctly determined by the Commissioner. Decision will be entered for the respondent. Trial memoranda had previously been submitted by the parties, and the trial judge agreed to accept revised or amended trial memoranda as setting forth the arguments of the parties. Petitioners presented their revised trial mem…
31. Treas. Reg. § 1.417(e)-1(d)(8)(ii) — Restrictions and valuations of distributions from plans subject to sections 401(a)(11) and 417.
    IRCRegulationsJan 19, 2024
    (d)(8)(ii) (ii) Optional delayed effective date of Retirement Protection Act of 1994 (RPA '94)(108 Stat. 5012) rules for plans adopted and in effect before December 8, 1994. For a plan adopted and in effect before December 8, 1994, the application of the rules relating to the applicable mortality table and applicable i…
32. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …
33. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …ear. The only persons covered by the Marlton Plan are Dr. Lo, Ms. Lo, and Edward Lo, 21 and, during 1994, the Marlton Plan purchased a separate insurance policy on the life of each of these persons. None of these persons, had he or she died, would have received a death benefit under the plan equal to eight times his or…
34. 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…
35. 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…
36. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995
    …transferred from the Retirement System to the Pension System. E.g., Hamilton v. Commissioner , T.C. Memo. 1994-633 (Baltimore County teacher who elected to transfer from Retirement System to Pension System and receive transfer refund in 1989 remained so employed at least through date of trial in 1994); see Hoppe v. Com…
37. 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…
38. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    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…
39. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    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…
40. T.C. Summary Opinion 2014-18 — Thomas Wesley Alexander & Sylvia Alexander v. Commissioner
    IRCCourt RulingsFeb 26, 2014related by meaning
    …nces of his or her transactions. Bezdjian v. Commissioner, 845 F.2d 217 (9th Cir. 1988), aff'g T.C. Memo. 1987-140; Carlton v. United States, 385 F.2d 238, 243 (5th Cir. 1967) (citing Commissioner v. Duberstein, 363 U.S. 278, 286 (1960)). What actually was done determines the tax treatment of a transaction. Weiss v. St…