IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
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 …
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…
T.C. Memo. 2007-30 — Estate of Carol Andrews, Deceased, Robert Andrews, Special Administrator, and Robert Andrews v. Commissioner IRCCourt RulingsFeb 7, 2007related by meaning
…
related to their investment in the partnerships; FPAAs were
- 25 -
13
Bales v. Commissioner
, T.C. Memo. 1989-568, involved
deficiencies determined against various investors in several Hoyt
partnerships. This Court found in favor of the investors on
several issues, stating that “the transaction in issue should be
resp…
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 RulingsJun 11, 1996related by meaning
…in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20303-94. Filed June 11, 1996.
Janet I. McCurdy
, for petitioners.
Alan…
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 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 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 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…
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 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 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…
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…
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…
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 …