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41. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    red all of petitioners’ arguments for contrary holdings; those arguments not discussed herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent necessary to reject or sustain each determination . We also have considered all of respondent’s arguments a…
42. PLR 200610016 — Year of Deduction
    IRCPrivate Letter RulingsMar 10, 2006related by meaning
    … 86,112 sets forth a defined set of circumstances in which the Service may apply a technical advice memorandum (TAM) that retroactively revokes an earlier TAM or ruling that involves a particular taxpayer. Section 16 of Rev. Proc. 2005-2, 2005-1 I.R.B. 86, 13 provides that under § 7805(b) an Associate Chief Counsel, as…
43. T.C. Memo. 1996-545 — Creston Swaim v. Commissioner
    IRCCourt RulingsDec 17, 1996related by meaning
    …e Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar. T.C. Memo. 1996-545 UNITED STATES TAX COURT CRESTON SWAIM, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20684-94. Filed December 17, 1996. Creston Swaim, pro se. Michael D. Zima , for respondent. MEM…
44. U.S. Tax Court — Susan Elizabeth Machlay v. Commissioner
    IRCCourt RulingsFeb 10, 2009related by meaning
    ic v . ,Commissioner , T .C . Memo . 1992-- 609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . . In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her medical condition . She explained at trial that although she received treatment from doctors in 2005, she did …
45. PLR 200118016 — Notification of Secretary of Labor
    IRCPrivate Letter RulingsMay 4, 2001related by meaning
    …30-00/CC:TEGE:EB:QP1 UILC: 4975.07-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area Attn: Laura Beth Heisen FROM: Michael Roach, Chief CC:TEGE:EB:QP1 SUBJECT: Adequacy of Department of Labor Notification Pursuant to I.R.C. §4975(h)…
46. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
47. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    …K-1 issued to petitioner indicates that petitioner's share of partnership liabilities at the end of 1990 was $69,756. Luther Thompson, a partner at Heidelberg & Woodliff, testified that he could not vouch for the accuracy of that figure because it was handwritten and not typewritten like the remainder of the schedule. …
48. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    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 …
49. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997related by meaning
    ng bank at the end of 1992. Based on our examination of the entire record before us, we find that petitioners have failed to show that they acted with reasonable cause and in good faith, or that they otherwise exercised due care or made a reasonable attempt to comply with the Code, when they claimed the 1992 and 1993 d…
50. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
51. Treas. Reg. § 54.4979-1(c)(4) — Excise tax on certain excess contributions and excess aggregate contributions.
    IRCRegulationsJul 26, 2017
    …he excess contributions or making qualified nonelective contributions (QNECs). (ii) On December 31, 1990, X determines that Y does not satisfy the actual deferral percentage test for the 1990 plan year, and that excess contributions for the year equal $5,000. On March 1, 1991, Y distributes $2,000 of these excess contr…
52. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    T.C. Memo. 1995-492 UNITED STATES TAX COURT GLENN L. WITTSTADT, JR. AND LYNNE M. WITTSTADT, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7123-93. Filed October 11, 1995. Robert G. Cassilly , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Jud…
53. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    ive taxable years from 1988 through 1990. Ms. Johnson received $20,580, $31,200, and $15,600 during the same respective years. Neither of the Johnsons received any compensation from Roofing during their 1991 through 1993 taxable years. The Johnsons filed timely their joint 1990 Federal income tax return. On March 3, 19…
54. T.C. Memo. 1997-324 — Douglas R. Prince, D.D.S., M.S., P.C. v. Commissioner
    IRCCourt RulingsJul 15, 1997related by meaning
    rporate payments to be compensation to petitioner when they were made. Paula Constr. Co. v. Commissioner , supra at 1059. Moreover, we decide the case in light of what was done, not what might have been done. Id. at 1060 (and cases cited therein). The record in the instant case lacks any credible evidence of the corpor…
55. DOL EBSA (final agency order) — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. NORTHWESTERN INSTITUTE OF PSYCHIATRY
    ERISACourt RulingsJul 26, 1995
    … will be forwarded to you when completed." The IRS sent NIP a second deficiency letter on March 20, 1990, noting that Schedule. B and the IQPA's opinion was still missing, and that some information was missing from the Schedule C that was provided, and reiterated the penalties which could be levied by the IRS and the D…
56. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    …ation software is only as good as the information one puts into it.”). 21 [* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526 (“ [The tax p ayers] argue that benefits received from the [RRB] are not taxable. This , however , is simply not the case.”). VIII. Conclusion Petitioners received railroad re…
57. 86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents
    IRCProposed Rules (FR)Proposed Jul 23, 2021
    was entered into before January 1, 1989, and— (A) The increase occurs before April 1, 1990, or (B) The amount of the increase does not exceed $50,000. (3) Illustration. (i) If federal executive agency enters into an initial contract on December 1, 1988, and the amount of money obligated under the contract is increased …
58. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…