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, 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 …
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
… *
(b) * * *
CFR part or section where identified and described Current OMB control No.
* * * * *
1.457-8 1545-1580
* * * * *
Robert E. Wenzel,
Deputy Commissioner for
Services and Enforcement. Approved July 2, 2003.
Pamela F. Olson,
Assistant Secretary of the Treasury (Tax Policy). Note
(Filed by the Office of the Fed…
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…
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…
IRCCourt RulingsDec 16, 1998related by meaning
regardless of whether
such events predate or postdate our announcement of
the rule. [ Harper v. Virginia Dept. of Taxation
,
509 U.S. 86, 97 (1993).] On the basis of the Supreme Court's opinion in Commissioner v.
Keystone Consol. Indus., Inc.
, 508 U.S. 152 (1993), we sustain
respondent's determination that petitioner…
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 RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
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…
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 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 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…
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 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 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…
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…