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Go to T.C. Memo. 1997-202 (not yet in the library — opens the official source)
55 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 85 FR 71016 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
    IRCProposed Rules (FR)Proposed Nov 6, 2020related by meaning
    f the Treasury, for issues related to Rapid Coverage of Preventive Services for Coronavirus. SUPPLEMENTARY INFORMATION: Inspection of Public Comments: All comments received before the close of the comment period are available for viewing by the public, including any personally identifiable or confidential business info…
  3. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  4. 89 FR 32260 — Amendment to Prohibited Transaction Exemption 2020-02
    ERISAFinal Rules (FR)Apr 25, 2024related by meaning
    Treasury. This clarification was in the preamble to the December 2020 grant of PTE 2020-02, and the Department is now adding it to the operative text. Although the proposed broader recordkeeping condition is consistent with other exemptions, the Department understands commenters' concerns that broader access to the doc…
  5. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
  6. 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…
  7. 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…
  8. 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…
  9. 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…
  10. 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…
  11. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    ication of a pending or planned examination or investigation as a result of information provided by the whistleblower. IRM pt. 25.2.2 (June 18, 2010). Additionally, the Tax Court has exclusive jurisdiction over appeals of award determinations where a whistleblower provided information both before and after the effectiv…
  12. 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…
  13. 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…
  14. DOL Office of Administrative Law Judges — USDOL, EBSA v. SCHNEIDERMAN'S FURNITURE, INC.
    ERISACourt RulingsMar 23, 2001
    qualified 1997 IQPA report. GX 5; RX B. 10. PWBA issued a Notice of Intent to Assess a Penalty on or about January 14, 2000, reiterating that the 1997 IQPA report was deficient because the scope of the audit was inappropriately limited,1 and proposing a penalty of $50,000 against Schneiderman's for its failure to file …
  15. T.C. Memo. 2023-141 — Danielle Monique Scott v. Commissioner
    IRCCourt RulingsNov 28, 2023related by meaning
    tion she received in 2019. ” Petitioner did not respond t o our Order by the October 2, 2023, deadline or subsequently. Discussion I. Summary Judgment The purpose of summary judgment is to expedite litigation and avoid costly, time-consuming, and unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (…
  16. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
  17. Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione…
    IRCRevenue ProceduresJan 2, 2013related by meaning
    P or EO Technical must mail the taxpayer its final administrative conclusion about the deletions to be made. When no copy is given to the taxpayer .06 If EP or EO Technical tells the EP or EO Examinations office or the EP or EO Determinations office or the Appeals Area Director that a copy of the TAM should not be give…
  18. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    is written, and, even if petitioner's argument might accord with good policy, we are not at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984))…
  19. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
    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…
  20. T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner
    IRCCourt RulingsMar 5, 2007
    …ive record does not show that respondent took the proceeds on the sale of the Murray’s house in mid-1997 before the Murrays filed their 1996 tax return around Apr. 15, 1997. the proceeds on the sale of the Murrays’ house in mid-1997, and petitioner and intervenor filed for bankruptcy in September 1997. We disagree. Int…