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41. 107 T.C. No. 16 — Schmidt Baking Company, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1996
    …. Filed November 14, 1996. P funded its vacation and severance pay obligations to its employees for 1991 by purchasing an irrevocable letter of credit on March 13, 1992. The letter of credit constituted a transfer of an interest in substantially vested property, includable in income of the employees as of that date und…
42. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012related by meaning
    …red by the Joint Committee on Taxation (the Blue Book); privatd letter rulings and technical advice memoranda issued after October 31, 1976; actions on decisions and general counsel memoranda issued after March 12, 1981 (as well as general counsel memoranda published in pre-1955 volumes of the Cumulative Bulletin); Int…
43. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997
    …ee and Trust Co. (the Delaware Charter IRA). 7 Distribution of the Loyola IRA On or about April 11, 1991, Loyola Federal Savings and Loan distributed, and petitioner received, the account balance of - 7 - petitioner's IRA; i.e., $90,662.11, which consisted of petitioner's initial deposit and earnings as follows: IRA de…
44. 122 T.C. No. 16 — Gregory Iannone v. Commissioner
    IRCCourt RulingsApr 19, 2004
    …ter notice and demand. Transcripts of your account show that the IRS issued a first notice July 19, 1991 and a fourth notice December 16, 1991 on your 1040 198712 [Federal income tax liability for the 1987 tax year], a first notice April 26, 1993 and a fourth notice May 17, 1993 on your 1040 198912 [Federal income tax …
45. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    v. Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo. 2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v. - 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001). While we acknowledge and are sympathetic to petitioner's financial straits, we have no aut…
46. 143 T.C. No. 11 — Dennis E. Bohner v. Commissioner
    IRCCourt RulingsSep 23, 2014related by meaning
    … not clearly contemplated by the Internal Revenue Code. See, e.g., Eichelburg v. Commissioner, T.C. Memo. 2013-269 at *7-*8 ("We acknowledge that the result we reach may seem harsh. * * * However, this Court may not rely on general equitable principles to expand the statutorily prescribed time for filing a petition." (…
47. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
48. T.C. Memo. 1995-594 — Steven M. & Michele E. Grow v. Commissioner
    IRCCourt RulingsDec 14, 1995
    …r the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1995-594 UNITED STATES TAX COURT STEVEN M. AND MICHELE E. GROW, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20185-94. Filed December 14, 1995. Steven M. and Michele E. Grow, pro se. Amy …
49. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    …to transgress the constitutional limitation: See, e.g., McGehee Family Clinic v. Commissioner, T.C.:Memo. 2010-202. The penalty structure of section 6662A does not do so Petitioners also contend that their due process rights have been violated because the language "substantially similár" set forth in Notice 2004 8, sup…
50. T.C. Memo. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    … v. Commissioner , 7 F.3d at 774, 778 (8th Cir. 1993), affg. in part and revg. in part 97 T.C. 385 (1991). date of transfer (October 19, 1990) made the transaction self-correcting * * *. See Zabolotny v. Commissioner , 7 F.3d 774 (8th Cir. 1993)", affg. in part and revg. in part 97 T.C. 385 (1991). Respondent argues th…
51. T.C. Summary Opinion 2001-69 — Marsha K. Huggins v. Commissioner
    IRCCourt RulingsMay 14, 2001related by meaning
    December 19, 1989, - 6 - for tax years ending after the date of enactment. See OBRA sec. 7841(a)(3), 103 Stat. 2428. The court order in this case was issued in 1985; it precedes the effective date of section 414(p)(11) and cannot qualify as a QDRO. The decree provided that petitioner is to receive a "sum of money equa…
52. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
53. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995related by meaning
    …397 (1974); Alexander v. Commissioner , 61 T.C. 278, 288 n.6 (1973); Stengel v. Commissioner , T.C. Memo. 1992-570, affd. without published opinion 996 F.2d 1227 (9th Cir. 1993); Cotter v. Commissioner , T.C. Memo. 1991-316. 4 For a discussion of the Retirement System and the Pension System, see generally Hylton v. Com…