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Go to T.C. Memo. 1997-469 (not yet in the library — opens the official source)
60 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    …petitioners’ 1996 joint return, petitioners claimed, - 23 - 16 Petitioners attached to petitioners’ 1997 joint return Form W-2 for 1997 for Mr. Whitehead (Mr. Whitehead’s 1997 Form W2). That form showed “BURIEN NISSAN ADMINISTRATION” as employer and Mr. Whitehead as employee. Mr. Whitehead’s 1997 Form W-2 showed, inter…
  2. 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…
  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. 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…
  5. 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…
  6. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    Parker, Judge: By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows: _Additions to tax_ Sec. Sec. Sec. TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1/31/86 $64,117 $3,206.85 50 percent $16,029.25 of the interest …
  7. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
  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. 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.…
  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. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    …otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1997-159 UNITED STATES TAX COURT ROBERT CHARLES FOHRMEISTER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11748-95. Filed March 31, 1997. Robert Charles Fohrmeister, pro se. D. Lyndell Pic…
  12. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000★ strong match
    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…
  13. 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…
  14. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    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 .…
  15. 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…
  16. 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…
  17. 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…
  18. 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…
  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. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997related by meaning
    …n all respects relevant for this case, to the proposed regulations. See Hall v. Commissioner , T.C. Memo. 1991-133. In general temporary regulations remain in effect until replaced by final regulations or withdrawn. Id. The temporary regulations in this case have been neither replaced nor withdrawn, so we rely on them.…