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 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.…
IRCCourt RulingsJun 18, 1999related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
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 …
IRCCourt RulingsApr 11, 2012
s.
On March 5, 1999, Mr. Cline sent to Dr. White a letter regarding his
attendance at the xélan seminar and the need to schedule a meeting to create a xélan tax reduction plan for Dr. White. Dr. White met with Mr. Cline on June 16,
1999, to discuss Dr. White's financial needs and the possibility of joining the
Economic…
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))…
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 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 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…
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…
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 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…
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 RulingsAug 1, 2005
…stified at trial, however, that he received
this amount in December 1998. The check, dated June 14, 1999,
clearly contradicts petitioner’s assertion.
6
Petitioner presented no evidence of the latter two
amounts that he claimed to have received from Americo in 1999.
1. Did petitioner receive the distributions at issue i…