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Go to T.C. Memo. 1997-115 (not yet in the library — opens the official source)
64 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    income tax return. Although the Court can appreciate petitioners' frustration, we must nevertheless note that matters involving interest do not, as a general rule, fall within the scope of this Court's jurisdiction. Perkins v. Commissioner , 92 T.C. 749, 752 (1989); LTV Corp. v. Commissioner , 64 T.C. 589, 597 (1975); …
  2. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    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…
  3. T.C. Summary Opinion 2001-178 — Dennis J. Lawless v. Commissioner
    IRCCourt RulingsNov 28, 2001
    …e conceded that he is not entitled to the $27 deduction, having never claimed this deduction on his 1997 income tax return in the first instance and having failed to address the issue before, during, or after the trial. Although petitioner’s 1997 income tax return reflects a claimed deduction of $5,807 for a contributi…
  4. 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…
  5. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996related by meaning
    T.C. Memo. 1996-421 UNITED STATES TAX COURT JOE M. AND PATRICIA M. BROWN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9129-93. Filed September 18, 1996. Robert O. Kazary , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was…
  6. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006
    …filing fee. In the amended petition, petitioners disputed deficiencies determined for taxable years 1997 and 2000, and they attached a notice of proposed changes (Form CP-2000), issued by respondent on June 9, 1999, proposing an increase to petitioners’ 1997 taxable income. The income at issue for taxable year 1997 was…
  7. 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.…
  8. T.D. 9166 — Final regulations under section 9801 of the Code provide guidance on the Health Insurance Portability and Accountability Act of 1996 (HIPAA) portability requir…
    IRCTreasury DecisionsFeb 22, 2005
    …l regulations implementing the HIPAA provisions were first made available to the public on April 1, 1997 (published in the Federal Register on April 8, 1997, 62 FR 16894) (April 1997 interim rules) (T.D 8716, 1997-1 C.B. 225). On December 29, 1997, the Departments published in the Federal Register (62 FR 67688) a clari…
  9. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ort the 10-percent additional tax, believing that he qualified for the disability exception. Although petitioner failed to qualify under the technical provisions of the Internal Revenue Code and the regulations, we - 13 - do not believe petitioner acted unreasonably or intentionally disregarded the rules and regulation…
  10. REG-130370-04 — Proposed regulations under section 9801of the Code would provide guidance on the HIPAA portability requirements relating to interaction with the Family and Med…
    IRCProposed Rules (FR)Proposed Feb 22, 2005
    …l regulations implementing the HIPAA provisions were first made available to the public on April 1, 1997 (published in the Federal Register on April 8, 1997, 62 FR 16894) (April 1997 interim rules) (T.D. 8716, 1997-1 C.B. 225). On December 29, 1997, the Departments published a clarification of the April 1997 interim ru…
  11. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    red all of petitioners’ arguments for contrary holdings; those arguments not discussed herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent necessary to reject or sustain each determination . We also have considered all of respondent’s arguments a…
  12. IRCRegulationsMay 18, 2016
    …ses of satisfying the current availability requirement of § 1.401(a)(4)-4(b) for the portion of the 1997 plan year before the amendment, the group of employees to whom the right to direct investments is currently available, taking into account the amendment, must satisfy the nondiscriminatory classification test of § 1…
  13. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    T.C. Memo. 1995-492 UNITED STATES TAX COURT GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7123-93. Filed October 11, 1995. Robert G. Cassilly , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Jud…
  14. T.C. Memo. 2012-346 — Esmat Zaklama, Deceased v. Commissioner
    IRCCourt RulingsDec 18, 2012
    …1992 through 1994 taxable years. The case at docket No. 9276-03 involves Ms. Zaklama's 1995 through 1997 taxable years. The remaining case involves Mr. Zaklama's 1995 through 1997 taxable years. We use the term "subject years" to refer collectively to Ms. Zaklama's 1992 through 1997 taxable years and to Mr. Zaklama's 1…
  15. T.C. Summary Opinion 2001-60 — Blaney H. Howle, III & Polly T. Howle v. Commissioner
    IRCCourt RulingsApr 23, 2001
    …titioners are husband and wife. Petitioner Blaney H. Howle III (Mr. Howle) turned 62 on October 31, 1997, and petitioner Polly T. Howle (Mrs. Howle) turned 62 on March 1, 1997. Mr. Howle has been retired on disability from railroad employment since the age of 57. In 1997, Mr. Howle received Tier 1 railroad retirement b…
  16. T.C. Summary Opinion 2001-5 — Fred P. & Patricia M. Brandkamp v. Commissioner
    IRCCourt RulingsJan 23, 2001
    spect of the taxable year 1997. Petitioners timely filed a joint Federal income tax return (Form 1040) for 1997. On their return, petitioners reported total income of $79,300, consisting of wages of $79,271 and taxable interest of $29. Petitioners deducted from total income the $2,000 amount that had been contributed t…
  17. 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…
  18. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    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…
  19. T.C. Summary Opinion 2005-183 — Jeffrey Thomas & Louise Marie Olup v. Commissioner
    IRCCourt RulingsDec 13, 2005
    …the date the contract is entered into or construction co mm ences ." S . Rept . 105-33 , at 30-31 ( 1997 ), 1997-4 C .B . (Vol . 2) 1067, 1110 ; H . Conf . Rept . 105-220 , at 381 (1997), 1997-4 C .B . (Vol . 2) 1457, 1851 ; H . Rept . 105-148 , at 338 (1997), 1997-4 C .B . (Vol . 1) 319, 660 . - 8 - Further, to broadl…
  20. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997related by meaning
    ng bank at the end of 1992. Based on our examination of the entire record before us, we find that petitioners have failed to show that they acted with reasonable cause and in good faith, or that they otherwise exercised due care or made a reasonable attempt to comply with the Code, when they claimed the 1992 and 1993 d…