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21. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
22. T.C. Memo. 2003-12 — Richard J. Meyer, III v. Commissioner
    IRCCourt RulingsJan 13, 2003
    …r) 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 Mr. M…
23. 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.…
24. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
25. 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…
26. Treas. Reg. § 1.414(r)-5(f)(5) — Qualified separate line of business—administrative scrutiny requirement—safe harbors.
    IRCRegulationsSep 9, 2016
    …ce conditions under any plan of the employer. All other employees of Line 1 and Line 2 on March 31, 1995 are nonexcludable employees for purposes of the average benefit percentage test during the 1995 testing period.(iii) In order for Line 1 to satisfy the requirements of this paragraph (f) for 1995, the actual benefit…
27. 117 T.C. No. 19 — The Board of Trustees of the Sheet Metal Workers' National Pension Fund, In Its Capacity As Plan Administrator v. Commissioner
    IRCCourt RulingsDec 4, 2001
    to a technical advice memorandum dated November 9, 1994 (regarding provisions not at issue in this case), as well as to comply with amendments to the Code. The application contained the amended and restated plan that petitioner adopted on December 22, 1994. It also contained a copy of a proposed amendment to article 8…
28. 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…
29. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996
    …t, the Transfer Refund was not a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995-492, Humberson v. Commissioner , T.C. Memo. 1995470; Pumphrey v. Commissioner , T.C. Memo 1995-469; Dorsey v. Commissioner , T.C. Memo. 1995-97, affd. without published opinion 91 F.3d 129 (4th Cir. 1996); Hyl…
30. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997related by meaning
    Motion for a Section 6673 Penalty Respondent submitted a motion for the imposition of a penalty under section 6673. Section 6673(a)(1) authorizes this Court to impose a penalty in favor of the United States in an amount not to exceed $25,000 whenever it appears that the taxpayer's position in a proceeding is frivolous,…
31. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    ng warned by the Court and after having received notice from the Court in a prior case. 6 On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's position is both frivolous and groundless. Accordingly, we exercise our discretion and award a penalty t…
32. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    s, earnings, and reasonable charges) pursuant tb Rev. Proc. 2005-25, 2005-1 C.B. 962. P may not : rŠduce the PERC value by the surrender charge, as it spould be disregarded for valuation purposes pursuant to Rev. Proc . 2005-25, lsupra. Held, further, P must include in his gross income the excess contributiorls pursuan…
33. 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
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
34. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000
    …er is liable for additions to tax under section 6654 for the failure to pay estimated taxes for the 1995 and 1996 taxable years; (5) whether petitioner is liable for accuracy-related penalties under section 6662(a) for the underpayment of taxes for the 1994 and 1995 taxable years; and (6) whether a penalty should be aw…
35. T.D. 9075 — Final regulations under section 457 of the Code provide guidance on eligible section 457 deferred compensation plans of state and local governmental employers …
    IRCTreasury DecisionsSep 29, 2003related by meaning
    rders) applies for transfers, distributions, and payments made after December 31, 2001. Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows: Authority: 26 U.S.C. 7805. Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
36. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997
    …r similar NOA agreements are independent contractors or employees. Mosteirin v. Commissioner , T.C. Memo. 1995-367; Smithwick v. Commissioner , T.C. Memo. 1993-582, affd. per curiam sub nom. Butts v. Commissioner , 49 F.3d 713 (11th Cir. 1995); Butts v. Commissioner , T.C. Memo. 1993-478, affd. per curiam 49 F.3d 713 (…
37. T.C. Summary Opinion 2001-8 — Peter Spuler, Jr. v. Commissioner
    IRCCourt RulingsFeb 2, 2001
    …Co Inc, SEP-IRA DTD 11/20/93". Contributions were made to the account in the amounts of $27,500 for 1995 and $30,000 for 1996. Petitioner also paid $3,079 and $4,570 for self-employed health insurance for 1995 and 1996. Petitioner’s father, Peter J. Spuler, Sr. (Mr. Spuler), died in 1995. During that year petitioner re…
38. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    …tioners submitted four successive offers-incompromise (OIC): on June 5, 1997 (with respect to their 1995 and 1996 income tax liabilities); on November 4, 1997 (with respect to their 1995 and 1996 income tax liabilities); on April 6, 2004 (with respect to their 1995, 1996, 1999, 2000, 2001, and 2002 income tax liabiliti…
39. Treas. Reg. § 1.410(b)-8(a)(5) — Additional rules.
    IRCRegulationsSep 9, 2016
    …ations on an employee's employment on the last day of the plan year. Plan A is being tested for the 1995 calendar plan year using the daily testing option in paragraph (a)(2) of this section. In testing the plan for compliance with section 410(b) on March 11, 1995, Employee X is taken into account because he was an emp…
40. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    IRCCourt RulingsFeb 12, 2008related by meaning
    oner , T .C . Memo . 2004-125 . - 6 - Petitioner has not argued, and she has failed to demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right . Consequently, we must uphold TRHCA section 408 if it bears a rational relationship to a legitimate govern…