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Go to T.C. Memo. 1992-153 (not yet in the library — opens the official source)
64 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1997-15 — Mark J. Vorwald v. Commissioner
    IRCCourt RulingsJan 8, 1997
    …ion. Background Some of the facts have been stipulated, and they are so found. Petitioner filed his 1992 Federal income tax return on June 15, 1995. He was single as of the close of 1992 and resided in Buellton, California, at the time that the petition was filed. In 1986, petitioner opened an individual retirement acc…
  2. 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…
  3. T.C. Memo. 1998-24 — Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders v. Commissioner
    IRCCourt RulingsJan 21, 1998
    iency Sec. 4971(b) Deficiency Sec. 6651(a) 1991 $772 --- $193 1992 1,310 $12,604 327 1993 3,250 31,999 812 1994 3,042 53,624 --- 1995 5,362 53,624 804 The second notice determined Federal excise tax deficiencies pursuant to section 4975 and additions to tax pursuant to section 6651 for 1992-95 (the second deficiency no…
  4. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  5. Treas. Reg. § 1.72-4(d)(3)(v) — Exclusion ratio.
    IRCRegulationsJul 26, 2016
    …le year 1993, to redetermine amounts to be received as an annuity under the contract as of June 30, 1992. The extent to which the amounts received in 1993 or thereafter shall be considered amounts received as an annuity is determined as follows: Pre-July 1986 investment in the contract allocable to taxable years 1991 a…
  6. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    IRCCourt RulingsNov 12, 1997
    … total 1991 tax - 8-8 liability to be $25,000, which was fully paid through withholdings. In August 1992, petitioner filed Form 2688 (Application for Additional Extension of Time To File U.S. Individual Income Tax Return) seeking an additional 2-month extension of the time to file his 1991 tax return because he was sti…
  7. 29 C.F.R. § 4022.61(f) — Limitations on benefit payments by plan administrator.
    PBGCRegulationsJan 1, 2017
    …ruptcy termination, see §§ 4022.21(e), 4022.22(b), and 4022.23(g).) Example 1. Facts.On October 10, 1992, a plan administrator files with the PBGC a notice of intent to terminate in a distress termination that includes December 31, 1992, as the proposed termination date. A participant who is in pay status on December 3…
  8. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. GEORGE H. ROBINSON, ADMINISTRATOR ANSWERING SERVICE, INC. ESOP
    ERISACourt RulingsFeb 2, 1993
    14, 1992, certain special procedural rules were prescribed for the presentation of evidence and argument by the parties in written form. In accordance with those procedural rules, Respondent's opening statement dated April 2, 1992, with attached Exhibits "A" through "I"; Pt/BA's opening statement dated May 24, 1992, wi…
  9. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
  10. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. SPALDING AND EVENFLO COMPANIES, INC.
    ERISACourt RulingsFeb 1, 1993
    Respondent's statement of reasonable cause, due January 13, 1992, that was filed subsequent to January 13 if Respondent describes in the statement of reasonable cause what is intended to be produced and a reasonable time frame within which to produce these items. This letter was received on or about January 8, 1992. 1…
  11. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CINPAC, INC./LIBBY LEE TOYS, INC.
    ERISACourt RulingsMar 20, 1995
    …e Department [of Labor]." The Respondent was also notified of the 45-day time limit in the April 3, 1992, letter of rejection, which it received on April 7, 1992. Respondent sent in the requested additional information by letter of May 21, 1992; 48 days after the date of the April 3, 1992, Notice, but only 44 days afte…
  12. 115 T.C. No. 33 — Sherwin-Williams Company Employee Health Plan Trust, Key Trust Company of Ohio, Trustee v. Commissioner
    IRCCourt RulingsNov 9, 2000
    …lified asset account, as defined in section 419A(a), was $64,615,936 5 for 1991 and $84,192,933 for 1992. The foregoing account limits for 1991 and 1992 included $53,313,236 and $71,602,395, respectively, attributable to a reserve for postretirement medical benefits. The Trust filed Forms 990, Return of Organization Ex…
  13. 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…
  14. 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…
  15. 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 …
  16. T.C. Memo. 1998-30 — Brian J. Patrick v. Commissioner
    IRCCourt RulingsJan 26, 1998
    …ts a finding that the transactions did not create bona fide debt. Cf. Fuller v. Commissioner , T.C. Memo. 1980-370 (taxpayers submitted evidence that their net worth substantially exceeded the sum of - 15 - the balances on the promissory notes, and thereby demonstrated their ability to repay the obligation). e. The Rel…
  17. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    …e year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1996-556 UNITED STATES TAX COURT ALFRED P. DUFFY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6723-93. Filed December 23, 1996. Alfred P. Duffy, pro se. Judith Wilkie , for respondent. ME…
  18. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    all of the contentions and arguments of the parties that are not discussed herein, and we conclude that they are without merit, irrelevant, or moot . "Para . 6 of the petition filed by each petitioner admits : "According to Section 6673, this court may penalize Petitioner up to $25,000 for failure to complete the admin…
  19. 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…
  20. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    to the additional tax under section 72(t) and distinguished Larotonda and Murillo on the ground that "the IRA distributions [in Czepiel] were not made without any active participation by" the taxpayer. Id. That is equally true of the distribution here. - 5 - To reflect the foregoing, An appropriate order of dismissal a…