IRCCourt RulingsAug 16, 2005
…king account where she
deposited her paychecks.
During the period from July 27 through December 31, 2001,
petitioner wrote checks totaling $66,082.07 drawn on the Harris
Trust & Savings Bank joint checking account as follows:
Date
Check No.
Description
Amount
7/27/2001 136 Payable to: Discover $2,700.00
8/1/2001 137 Pa…
IRCCourt RulingsDec 19, 2000related by meaning
…etermined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice of deficiency was not an
affected items notice…
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…
IRCCourt RulingsJun 2, 2005
that they filed their petitions.
Petitioners timely filed joint Federal income tax returns
for 2001 and 2002. During 2001 and 2002, petitioner was an active participant in a section 403(b) employer-sponsored
retirement plan through his employment with the University of
Texas Medical Branch. Petitioner claimed IRA cont…
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 RulingsJan 3, 2011★ strong match
… provided Table 2001
as a substitute for the P.S. 58 rates
In, Curc io-v . Commis s ioner , T . C . Memo 2010 -115 , we used the
rates in section 1.79-3 (d) , Income Tax Regs. as a "rough
estimate" of'the cs c life insurance protection to. decide
whether the taxpayer s expenses for fife iËsuranck Were
deductible pursua…
IRCCourt RulingsOct 25, 2012
…lus any future cost of living or inflation increases permitted by the Internal Revenue Service.
The 2001 plan definition was amended effective July 1, 2001, reducing the
$200,000 limitation to amounts in excess of $150,000. The 2001 plan also defined
"compensation" to include any elective deferral and amounts contribut…
IRCCourt RulingsMar 1, 2016
ent
correspondingly adjusted each of petitioners' 2001 returns by, inter alia,
subtracting the JVC Trust distributions from their gross incomes. These adjustments resulted in tax abatements of $14,359 for petitioner and $27,105 for
Brian L. Costello. In January 2005, petitioners signed Forms 4549 with respect to
these …
T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner IRCCourt RulingsMar 5, 2007
…tion 6015(f), the Appeals officer said that petitioner had
$1,764 of disposable income per month in 2001, and that her
income had increased since then. That amount roughly equals the
excess of petitioner’s monthly income (including child support)
in 2001 of $4,184 over the six monthly expenses petitioner listed
on May …
IRCCourt RulingsAug 8, 2005
T.C. Memo. 2005-192
UNITED STATES TAX COURT
ARTHUR F. MILLARD, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 3713-04. Filed August 8, 2005.
Arthur F. Millard, pro se.
Travis T. Vance III
, for respondent.
MEMORANDUM OPINION
WELLS, Judge
: Respondent determined a deficiency of $2,764
in petition…
IRCCourt RulingsAug 28, 2008related by meaning
T .C . Memo . 2008-20 4
UNITED STATES TAX-COUR T
WALTER KOWSH, Petitioner v .
COMMISSIONER OF . INTERNAL . REVENUE, Responden t
Docket No . 15154-06 . Filed August 28, 2008 .
Walter Kowsh, pro se .
Michelle L . Maniscalco , for respondent .
MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N
KROUPA, Judge : Respondent determined…
IRCCourt RulingsMar 20, 2006
ICE
dAL.
T.C. Memo. 2006-47
UNITED STATES TAX COURT
DIEP N. HOANG, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4853-04. 042 Filed March 20, 2006.,
W. Michael Thornton. (specially recognized), for petitioner.¹
Francis C. Mucciolo and Lauren B. Epstein, for respondent.
MEMORANDUM FINDINGS OF FAC…
IRCPrivate Letter RulingsNov 2, 2001
…ued. This ruling is directed only to Agency A and applies only to the Plan submitted
on January 12, 2001, as revised by the amendments submitted on July 24, 2001 and to
the annuity contract submitted on January 12, 2001. In addition, no opinion is
expressed regarding the recently submitted Plan amendments which are int…
T.D. 9176 — Final regulations under section 411 of the Code reflect the addition of section 411(d)(6)(E) by the Economic Growth and Tax Relief Reconciliation Act of 2001 (… IRCTreasury DecisionsMar 7, 2005related by meaning
Rev. Proc. 2000-20 modified and superseded. Rev. Procs. 2005-6 and 2005-8 and Announcement 2001-77 modified.
EXEMPT ORGANIZATIONS
T.D. 9175 T.D. 9175 Temporary and proposed regulations under sections 6011, 6033, and 6037 of the Code affect certain corporations and organizations filing returns. These regulations requir…
IRCCourt RulingsMar 12, 2008
…ners contend that
the balance in petitioner's OCTFCU IRA was $51,118 .05 on December
1, 2001 .
In a memorandum dated November 7, 2006, to respondent's
attorney, petitioner attempts to explain how he had arrived at
"$286,000", the account balance he used in his calculation of
substantially equal periodic payments . Peti…
Rev. Rul. 2004-20 — Section 412(i) plans; deductibility; listed transactions. This ruling gives an example where a qualified pension plan cannot be a section 412(i) plan if the pl… IRCRevenue RulingsMar 8, 2004
…n Rev. Rul. 55-747 in determining the cost of insurance under a trust described in § 401(a). Notice 2001-10, 2001-1 C.B. 459, revoked Rev. Rul. 55-747, and provided a new table (Table 2001) to be used in valuing term life insurance coverage provided to an employee. Under Notice 2001-10, taxpayers could continue to use …
IRCCourt RulingsMay 8, 2006related by meaning
…ther petitioner had any overpayment with respect to taxable
year 2002.
petitioner’s overpayment for 2001.
10 The disallowance of the
credit that petitioner claimed with respect to this item does not
affect the amount of petitioner’s deficiency for 2002. See sec.
6211(a) (defining a deficiency generally as the amount by…
IRCCourt RulingsMay 29, 2002related by meaning
… however, there was no levy by respondent in this case.
Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13,
affd. without published opinion 166 F.3d 1201 (2d Cir. 1998),
also cited by petitioner, the taxpayer was indicted on charges of
violating Federal currency transaction reporting laws. As part
of the taxpaye…
IRCCourt RulingsJun 13, 2017related by meaning
and after the effective date of section 7623(b). See Whistleblower 1133213W v. Commissioner, 142 T.C. 396. In that case we held that the determinative issue is whether the whistleblower alleged facts that, if proven, would establish
that the Commissioner proceeded against the targets using information that the
whistleb…
IRCCourt RulingsMar 22, 2007
ailure to file an
income tax return for 2001 and under section 6654(a) for failure
- 6 -
to make estimated tax payments for 2001. Respondent bears the burden of production with respect to petitioner’s liability for
the additions to tax. Sec. 7491(c); Higbee v. Commissioner
, 116
T.C. 438, 446-447 (2001). To meet his bu…