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56 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    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…
  2. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    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…
  3. T.C. Memo. 1997-346 — William L. Reese v. Commissioner
    IRCCourt RulingsJul 29, 1997related by meaning
    …e, e.g., Day v. Commissioner , 975 F.2d 534, 538 (8th Cir. 1992), affg. in part, revg. in part T.C. Memo. 1991140; Liddy v. Commissioner , 808 F.2d 312, 315 (4th Cir. 1986), affg. T.C. Memo. 1985-107. Petitioner has failed to prove facts to contradict respondent’s determination of an addition to tax in the amount of $5…
  4. 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 …
  5. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    Parker, Judge: By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows: _Additions to tax_ Sec. Sec. Sec. TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1/31/86 $64,117 $3,206.85 50 percent $16,029.25 of the interest …
  6. 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. …
  7. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ions to tax under section 6651(a)(2) and that the addition to tax under section 6651(a)(1) for 1993 is not larger than $7,959. We sustain respondent's determination that petitioners are liable for additions to tax under section 6651(a)(1), except as conceded by respondent. Decision will be entered under Rule 155 .
  8. T.C. Memo. 2005-86 — Lisa Beth Levine v. Commissioner
    IRCCourt RulingsApr 14, 2005
    …/employer relationship. See, e.g., Eren v. Commissioner , supra ; Marckwardt v. Commissioner , T.C. Memo. 1991-347; Juliard v. Commissioner , T.C. Memo. 1991-230; Matt v. Commissioner , T.C. Memo. 1990-209. - 31 - Other cases have found that the taxpayer was an independent contractor. See, e.g., Chin v. United States ,…
  9. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
  10. 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…
  11. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
  12. 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…
  13. 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…
  14. 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 …
  15. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2002, the taxable year in issue. T.C. Summary Opinion 2006-184 UNITED STATES TAX COURT WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 23979…
  16. 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…