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…
ERISACourt RulingsNov 8, 1996
…SA. DOL alleged that
Respondent failed to timely file its 1993 Form 5500 Annual Report. On June 12, 1996, Respondent filed a Statement of Reasonable Cause
with DOL. DOL issued a Notice of Determination on Statement of
Reasonable Cause on July 8, 1996. Therein, DOL waived $8,050 of the
original civil money penalty. A ci…
IRCCourt RulingsOct 3, 1995related by meaning
…e year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10066-93. Filed October 3, 1995.
Harold L. Humberson, pro se.
Alan R. Pere…
IRCCourt RulingsJul 31, 2000
…fe Ins. Co. v. Commissioner
, 106 T.C. 274, 302 (1996); see also
M.I.C. Ltd. v. Commissioner
, T.C. Memo. 1997-96; Proios v.
Commissioner
, T.C. Memo. 1994-442. Other times, he or she will
not. See, e.g., Estate of Scanlan v. Commissioner
, T.C. Memo.
1996-331, affd. without published opinion 116 F.3d 1476 (5th Cir.
19…
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…
ERISACourt RulingsOct 14, 1999
…ther stated that, at the time, Comgraphix had engaged the Lauterbach accounting firm to
perform the 1996 audit, but shortly thereafter, Ben Marmande, CFO
of Racom, told Comgraphix representatives that he had consulted
with an ERISA attorney and had been advised that, under the
circumstances, the annual report could be …
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 …
IRCCourt RulingsApr 12, 2000
itioner in taxable years 1995
and 1996 are includable in gross income. We hold they are. (3)
Whether individual retirement account (IRA) distributions received by petitioner in taxable years 1995 and 1996, as well as
pension and annuity distributions received by petitioner in
taxable year 1996, are includable in gross …
IRCCourt RulingsDec 11, 2003related by meaning
… 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 RulingsDec 18, 2012
…2
Respondent determined that each petitioner realized one-half of the total rental income for 1995, 1996, and 1997. These amounts are as follows:
1995 1996 1997
Deposited rent $17,908 $41,810 $2,730
Additional rent 16,087 15,355 19,542
Total rent 33,995 57,165 22,272
1/2 of rent 16,998 28,583 11,136
- 15 -
[*15] VII. T…
IRCCourt RulingsMay 14, 2001
…ly, $84.89 was automatically contributed
to the plan by WCC from petitioner’s total compensation in 1996
of $2,830. In order to qualify to receive benefits under the plan,
petitioner must earn at least 10 years of credited service and be
at least 60 years old. A single credit year is earned upon
performing Michigan pub…
IRCCourt RulingsMay 13, 1999
does not include:
- 17 -
8
The Small Business Job Protection Act of 1996, Pub. L. 104188, sec. 1434(a), 110 Stat. 1807, added sec. 415(c)(3)(D) which includes certain deferrals in participant's compensation,
effective for years beginning after Dec. 31, 1997. This
amendment does not apply to the instant case. We note, …
IRCCourt RulingsSep 25, 1996related by meaning
…iencies............................... 146
C. No Need To Address Other Issues............ 151
- 5 -
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge
: In seven of these consolidated cases
respondent determined deficiencies in Federal income taxes as
follows:
Taxable
Docket No.
Petitioners
Year
Deficiency
13364-89 B…
IRCCourt RulingsOct 19, 2010related by meaning
… •
warnings that he was in danger of being penalized. For example,
in Mathews v. Commissioner, T.C. Memo. 2005-84, we told
petitioner:
"Even though the filing of the petition resulted in
respondent's concession of the sec. 72(t) additional tax,
IRCCourt RulingsJun 18, 1999related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
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 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…
IRCCourt RulingsAug 8, 2000
…of Debtor under the chapter 11 proceeding was
entered on July 18, 1994, by the bankruptcy court.
In 1996, petitioner received IRA distributions of $12,905.89
from Fidelity Service Co. (Fidelity).
3
Though petitioner
reported total IRA distributions of $12,905.89 on line 15a of his
1996 Federal income tax return, he rep…
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 …
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…