IRCCourt RulingsFeb 18, 2004
ial goals, petitioner formed
Anthony Sadberry Family Trust No. 1 (the Trust) in 1999 to
finance Andrea's education and provide for her in the event of his death or incapacity. The Trust was assigned its own tax
identification number in March 1999 and was funded in part by the
net proceeds of the SFB distributions.9 In …
IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner IRCCourt RulingsFeb 21, 2024
e ,
dividend income, and interest income for t ax years 1999
through 2004 in the following amounts :
1999 2000 2001 2002 2003 2004
Net business
income $185,430 $121,207 $459,898 $502,412 $194,351 $153,593
Dividend
income
30 46 62 200 200 200
Interest
income
465 13,610 2,479 1,055 757 988
2. Whether p etitioners failed …
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 …
IRCCourt RulingsJan 27, 1998related by meaning
began on the date that the
prohibited transaction occurred, May 31, 1988, and ended on the
-14-
8
Petitioner contends that the second-tier tax of sec. 4975(b) is not applicable because of ERISA sec. 502(i), 29 U.S.C.
1132(i) (1988). ERISA sec. 502(i) provides the following:
In the case of a transaction prohibited by se…
IRCCourt RulingsMay 14, 2009
oners' 1999 Schedule
E shows that petitioners reported $22,980 of total rent received,
$29,457 of total expense deductions, and $7,318 of depreciation expenses, which resulted in rent and royalty losses of $13,796
._
for 1999
. Respondent's'computer printout of petitioners' 2001
Schedule E shows that petitioners did no…
IRCCourt RulingsJun 24, 2003
…h Smith reported to the Internal Revenue Service (IRS) that Ms. Potter received $3,038 of income
in 1999. Petitioners did not report this amount as income on
either their 1999 Form 1040, U.S. Individual Income Tax Return,
or their 1999 Form 1040X, Amended U.S. Individual Income Tax
Return.
In March 1999, both Ian Potte…
IRCCourt RulingsDec 20, 2002
… of argument that she has attempted to do
so.
- 6 -
2 The cursory description of sec. 412(a) of the 1999 Act in
the conference report provides no help. See H. Conf. Rept. 106478, at 61 (1999).
Petitioner and the mother have not married for economic
reasons. They explain that if they were to marry, the mother
would be d…
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…
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 .…
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…
IRCCourt RulingsJan 30, 2007
…00 and $62,930, and the check for $27,000,
for total distributions of $589,930.
042 D. Petitioners' 1999 Federal Income Tax Return
Petitioners filed a joint Federal income tax return for 1999
on June 18, 2003.3 Petitioners reported adjusted gross income of
$564,156, itemized deductions of $427,211, a total tax of
$33,7…
IRCPrivate Letter RulingsMar 3, 2000
…SAR's immediately prior to the sale, at which time the SAR's would otherwise terminate.
On June 30, 1999, a change of control and recapitalization of X, resulted in X becoming a
C corporation. Thus, January 1, 1999 - June 29, 1999, constituted a short tax year for X
as an S corporation ("the S Short Year") and June 30,…
IRCCourt RulingsJun 25, 2012related by meaning
other grounds, and
remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206;
Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 -
II. Administrative Costs
The administrative costs at issue are costs that petitioner incurred from the .
time respondent issued the notice of deficiency up to the …
IRCCourt RulingsOct 24, 2007
… an IRS stamp showing it was received by the IRS on May 30,
2000.
The joint return for taxable year 1999 shows a typed date of
“11-02-00” next to the signature of the paid return preparer.
- 12 -
The 1999 return also shows a typed date of “11-02-00” next to
both petitioner’s and Mr. Barrera’s signatures. The 1999 retur…
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…
IRCCourt RulingsOct 20, 2003
… Ford
and moved to Georgia. Petitioner started construction on his
- 4 -
Georgia residence in March 1999. At some time in 1999,
petitioner transferred his ownership interest in the Michigan
residence to his former wife. Petitioner and his former wife
divorced in November 2002.
During 1999, petitioner withdrew $50,674 f…
IRCCourt RulingsSep 30, 2003
… used
the remaining $12,880.04 to pay tuition and education fees to
Villanova University during the 1999 taxable year. Neither
petitioner attained the age of 59½ years during the 1999 taxable
year.
- 3 -
On April 15, 2000, petitioners filed a Form 1040, U.S.
Individual Income Tax Return, for the 1999 taxable year (1999…
IRCCourt RulingsMar 15, 2004
…nd Ann E. Owens, husband
and wife, were born on July 20, 1934, and March 29, 1941,
respectively. In 1999, petitioners owned multiple IRA accounts,
including a Fidelity Investments Traditional IRA in the name of
Howard T. Owens, Jr., and a Fidelity Investments Traditional IRA
in the name of Ann E. Owens. As of early May…
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,