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Go to T.C. Memo. 1992-335 (not yet in the library — opens the official source)
64 documents · 0.25sAllIRCERISAPBGCJoint Board
  1. 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 …
  2. 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…
  3. 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…
  4. 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…
  5. 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…
  6. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    e not binding on any government agency other than the United States Department of Labor." On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise tax deficiencies pursuant to section 4975(a) and (b), as well as additions to tax. Respondent determine…
  7. 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…
  8. 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’ …
  9. 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…
  10. 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…
  11. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996related by meaning
    …iencies............................... 146 C. No Need To Address Other Issues............ 151 - 5 - MEMORANDUM FINDINGS OF FACT AND OPINION BEGHE, Judge : In seven of these consolidated cases respondent determined deficiencies in Federal income taxes as follows: Taxable Docket No. Petitioners Year Deficiency 13364-89 B…
  12. 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…
  13. U.S. Tax Court — Cynthia M. Martinez v. Commissioner
    IRCCourt RulingsDec 29, 2008
    … 641 (9th Cir . 2008) (quoting United States v . Plummer 174 Bankr . 284, 286 (Bankr . C .D . Cal . 1992)) . Nonetheless, in reexamining the table supra page 5, we note that even accepting respondent's application as given, petitioner has paid more than her share of the liabilities for 1992 and 1995 . Further, if one w…
  14. 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…
  15. 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…
  16. T.C. Memo. 2016-33 — Sally M. Costello v. Commissioner
    IRCCourt RulingsMar 1, 2016related by meaning
    ion provisions allow for the correction of an error made in a closed tax year by extending the limitations period up to one year from the date a - 8 - [*8] final determination is made. Secs. 1311, 1314(b); see Beaudry Motor Co. v. United States, 98 F.3d 1167, 1168 (9th Cir. 1996). Their intent is to take "the profit ou…
  17. 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…
  18. T.C. Memo. 1997-319 — James B. & Joan E. Murtaugh v. Commissioner
    IRCCourt RulingsJul 9, 1997related by meaning
    …n all respects relevant for this case, to the proposed regulations. See Hall v. Commissioner , T.C. Memo. 1991-133. In general temporary regulations remain in effect until replaced by final regulations or withdrawn. Id. The temporary regulations in this case have been neither replaced nor withdrawn, so we rely on them.…
  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. 1998-443 — Michael Morrissey v. Commissioner
    IRCCourt RulingsDec 16, 1998related by meaning
    xcise tax returns could have concluded that the relevant transfer was not a prohibited transaction, or, if it was, that it had been corrected earlier. We have carefully considered all remaining arguments made by the parties for holdings contrary to those expressed herein, and, to the extent not discussed above, find th…