ERISACourt RulingsFeb 22, 2000
5 and 1996 to PWBA for review and
comment.
(e) By December 31, 1998, send finalized
versions of the 1995 and 1995 summary draft Annual Reports for the Plan participants.
(f) By December 31, 1998, pay a compromised
penalty payment of $15,000.00 to the Department.
On October 16, 1998, Respondent submitted the
draft Form …
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))…
IRCCourt RulingsDec 16, 1998related by meaning
xcise tax returns could have concluded that the relevant
transfer was not a prohibited transaction, or, if it was, that
it had been corrected earlier. We have carefully considered all remaining arguments made
by the parties for holdings contrary to those expressed herein,
and, to the extent not discussed above, find th…
IRCRegulationsSep 17, 2024
…3)(B). Q-8. Is there an exception to the income-inclusion rule described in A-7 of this section for 1998 conversions? A-8. Yes. In the case of a distribution (including a trustee-to-trustee transfer) from a traditional IRA on or before December 31, 1998, that is converted to a Roth IRA, instead of having the entire tax…
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…
IRCRegulationsMay 18, 2016
(d) (d) The rules in this A-3 are illustrated by the following examples: Example 1.In 1998, unmarried, calendar-year taxpayer B, age 60, has modified AGI of $40,000 and compensation of $5,000. For 1998, B can contribute a maximum of $2,000 to a traditional IRA, a Roth IRA or a combination of traditional and Roth IRAs. …
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); …
IRCRegulationsMay 18, 2016
…ransferred in a tax-free transfer to another Roth IRA prior to the recharacterization. Example 2.In 1998, an individual makes a $2,000 regular contribution for 1998 to his traditional IRA (FIRST IRA). Prior to the due date (plus extensions) for filing the individual's Federal income tax return for 1998, he decides that…
IRCCourt RulingsDec 29, 2008
…xes . After 2 years the law firm completed the returns and dated its preparer signature
October 19, 1998 . The Martinezes dated their signatures October
30, 1998, and they promptly filed the returns such that
respondent recorded receiving the returns on November 4, 1998 .
Regarding the final 2 years at issue, 99 percen…
IRCPrivate Letter RulingsAug 27, 1999related by meaning
…Number: 199934002
Release Date: 8/27/1999
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Taxpayer's Name:
Taxpayer's Address:
Taxpayer's Ident. No.:
Taxable Years at Issue:
Date of Conference:
Legend
:
Taxpayer =
Plan =
Trust Agreement =
ISSUES
:
(1) Whether, under the rules of section 461 of the …
IRCCourt RulingsJan 28, 2002
T.C. Memo. 2002-30
UNITED STATES TAX COURT
DREW ALLEN RAYNER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5749-00. Filed January 28, 2002.
Drew Allen Rayner, pro se.
Linda J. Wise
, for respondent.
MEMORANDUM OPINION
COLVIN, Judge
: Respondent determined that petitioner has an
income tax defi…
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
…th anniversary date preceding the enrollment date. For example, for an enrollment date of August 1, 1998, the 6-month period preceding the enrollment date is the period commencing on February 1, 1998, and continuing through July 31, 1998. As another example, for an enrollment date of August 30, 1998, the 6-month period…
IRCCourt RulingsMar 1, 2016related by meaning
ion provisions allow for the correction of an error made in a
closed tax year by extending the limitations period up to one year from the date a
- 8 - [*8] final determination is made. Secs. 1311, 1314(b); see Beaudry Motor Co. v.
United States, 98 F.3d 1167, 1168 (9th Cir. 1996). Their intent is to take "the
profit ou…
IRCCourt RulingsApr 2, 2024related by meaning
is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8
(2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on
the date which is 60 days after the later of . . . [the] earliest incident date . . …
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…
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
rders) applies for transfers, distributions, and payments made after December 31, 2001.
Part 602—OMB CONTROL NUMBERS UNDER THE PAPERWORK REDUCTION ACT Par. 4. The authority citation for part 602 continues to read as follows:
Authority: 26 U.S.C. 7805.
Par. 5. In §602.101, paragraph (b) is amended by adding an entry in …
IRCCourt RulingsMay 22, 2003
83 (all amounts are rounded).
Petitioners timely filed a 1998 Federal income tax return.
On the 1998 return, petitioners reported $32,628 on Line 16a, Total pensions and annuities, and $15,715 on Line 16b, Taxable
amount.
For the taxable year 1998, the Teachers’ Retirement System
of Louisiana issued to petitioner a For…
IRCCourt RulingsAug 25, 1997related by meaning
motion for costs
was filed out of time and should be "dismissed" for that reason.
We reject respondent's contention and do not consider it further.
12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA),
Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is
generally applicable to proceedings commenced after …
IRCCourt RulingsFeb 15, 2002
tioner’s 1998
Federal income tax and an addition to tax under section
6651(a)(1) of $3,433 and $321, respectively. After concessions
by the parties,
2 the issues are (1) whether petitioner is liable
for the additional tax under section 72(t) and (2) whether
petitioner is liable for the addition to tax under section
665…
IRCCourt RulingsJul 16, 2003
…uce her
workday to 4 hours.
Petitioner temporarily stopped meeting with Dr. Labovitz after July 31, 1998. Petitioner then reentered the hospital in
October 1998 and stayed there for approximately 2 weeks, after
which time she began meeting with Dr. Labovitz again. By letter
dated December 18, 1998, Dr. Labovitz stated …