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Go to T.C. Memo. 1998-461 (not yet in the library — opens the official source)
71 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 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…
  2. 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 .…
  3. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CURRENT DEVELOPMENT CORPORATION
    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 …
  4. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  5. T.C. Memo. 1996-265 — Harold E. & Anna Mae Emmons v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    …he Retirement System and the Pension System as a single pension plan. Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissioner , T.C. Memo. 1995-93; Hoppe v. Commissioner , T.C. Memo. 1994-635; Hamilton v. Commissioner , - 13 - T.C. Memo. 1994-633; see Wheeler v. Commissioner , T.C. Memo. 1993-561; see also S…
  6. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998★ strong match
    …stituted a modification of the terms of the notes. We have previously noted that a technical advice memorandum is merely a ruling given to a specific taxpayer based upon the taxpayer's specific facts and is not a ruling of general application. See Golden Belt Tel. Association, Inc. v. Commissioner , 108 T.C. 498, 506 (…
  7. 101 T.C. 489; 101 T.C. No. 32 — Powell v. Commissioner
    IRCCourt RulingsNov 29, 1993related by meaning
    aws. As to the precedential value of Memorandum Opinions, see, e.g., Newman v. Commissioner, 68 T.C. 494, 502 n.4 (1977). [Id. at 67; emphasis added.] In light of our restrained articulation in Darby, and particularly its caveat as to a community property situation, we are satisfied that Darby does not compel a decisio…
  8. Treas. Reg. § 1.408A-4(c) — Converting amounts to Roth IRAs.
    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…
  9. Treas. Reg. § 1.408A-3(d) — Contributions to Roth IRAs.
    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. …
  10. 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…
  11. Treas. Reg. § 1.408A-5(c) — Recharacterized contributions.
    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…
  12. U.S. Tax Court — Cynthia M. Martinez v. Commissioner
    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…
  13. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    INCOME TAX Rev. Rul. 2006-41 Rev. Rul. 2006-41 LIFO; price indexes; department stores. The June 2006 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with referenc…
  14. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    2,803.75 12/31/88 11,215 -- -- $560.75 2,803.75 12/31/89 11,215 -- -- -- 2,803.75 12/31/90 11,215 -- -- -- 2,803.75 12/31/91 11,215 -- -- -- 2,803.75 12/31/92 11,215 -- -- -- 2,803.75 12/31/93 11,215 -- -- -- 2,803.75 08/18/94 -- $224,298 -- -- -- This case involves the question of whether an assignment of accounts re…
  15. T.C. Memo. 2002-30 — Drew Allen Rayner v. Commissioner
    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…
  16. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    regardless of whether such events predate or postdate our announcement of the rule. [ Harper v. Virginia Dept. of Taxation , 509 U.S. 86, 97 (1993).] On the basis of the Supreme Court's opinion in Commissioner v. Keystone Consol. Indus., Inc. , 508 U.S. 152 (1993), we sustain respondent's determination that petitioner…
  17. 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…
  18. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    IRCCourt RulingsDec 19, 2000related by meaning
    limitation would have expired. - 11 - Nor does the fact that respondent had already issued petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected items notice of deficiency to petitioners for the same year. See sec. 6230(a)(2)(C); Hemmings v. Commissio…
  19. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    … • warnings that he was in danger of being penalized. For example, in Mathews v. Commissioner, T.C. Memo. 2005-84, we told petitioner: "Even though the filing of the petition resulted in respondent's concession of the sec. 72(t) additional tax,
  20. PLR 200009002 — Treatment of Funded Welfare Benefit Plans
    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 …