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…
IRCCourt RulingsOct 23, 2001
l January 17 , when she was
laid off. The official termination date on CP&L records is March
20, 1996. During her employment with CP&L, petitioner was covered by an employer pension plan. She was vested in the CP&L
pension plan. Petitioner contributed $1,175.46 to the CP&L
pension plan in 1996. Even though her employme…
IRCCourt RulingsOct 3, 1995related by meaning
rred to and remained within the Pension System.
By choosing to transfer to the Pension System, * * *
[Taxpayer] opted * * * to receive a refund of his contributions and accumulated interest along with
reduced annuity payments in the future
. Thus, in
effect, Taxpayer elected to receive the "balance to the
credit" of hi…
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 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 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…
T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409… IRCTreasury DecisionsJan 18, 2005related by meaning
INCOME TAX
Rev. Rul. 2005-3 Rev. Rul. 2005-3
Section 901(j)(5) Presidential waiver; Libya. Pursuant to a section 901(j)(5) Presidential waiver, section 901(j)(1) of the Code ceased to apply to Libya effective December 10, 2004. Section 911(d)(8) is not applicable to Libya after September 20, 2004, and Iraq after July 2…
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 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…
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 RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…
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 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 RulingsAug 30, 2006
…sion and an
anxiety disorder.
Petitioner’s difficulties with his supervisor continued
until January 1996. At that time, petitioner’s mental health had
deteriorated to the point that his physician recommended he stop
working at the Animal Control Division. In accordance with this
recommendation, petitioner left the Anim…
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…
IRCCourt RulingsFeb 2, 2001
property under the will.
Petitioner received automatic extensions to file his 1995
and 1996 Federal income tax returns. The due date of the 1995
- 5 - and 1996 returns as extended were August 15, 1996, and August 15,
1997, respectively. Petitioner’s 1995 and 1996 tax returns were
received by respondent on August 21, 19…
122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner IRCCourt RulingsFeb 9, 2004
…9, 2004.
P, prior to his death, sold all of his shares in C to
C’s employee stock ownership plan in 1996. P purchased
qualified replacement property with most of the proceeds
from the sale within a year of the sale. P’s 1996 original
Federal tax return was filed timely (i.e., on or before Apr.
15, 1997) and did not rep…
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
T.C. Memo. 1999-80
UNITED STATES TAX COURT
EDWARD CLASBY AND C.T. GARRAHAN INSURANCE AGENCY, INC.,
Petitioners v
. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1616-97. Filed March 16, 1999.
Paul F. Markham
, for petitioners.
Mark L. Hulse
and Gary W. Bornholdt
, for respondent.
MEMORANDUM FINDINGS OF FACT A…