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41. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999
    for the 5-percent excise tax on prohibited transactions under section 4975(a) for 1982 to 1993. 2. Whether petitioners are liable for additions to tax under section 6651(a)(1) for 1982 to 1993. We hold that they are to the extent discussed below. At trial, respondent conceded that petitioners are not liable for the 100…
42. 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…
43. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004related by meaning
    …ent’s litigating position that the distribution occurred in 2000. See Garcia v. Commissioner , T.C. Memo. 1998-203 (reaching this conclusion regarding another question and answer contained in the same proposed regulation), affd. without published opinion 190 F.3d 538 (5th Cir. 1999). Additionally, the substantially lev…
44. Treas. Reg. § 1.401(a)(4)-13(e)(2) — Effective dates and fresh-start rules.
    IRCRegulationsMay 18, 2016
    …6-464, 1976-2 C.B. 115, with respect to all years credited under the stated benefit formula through 1993. The plan provides a stated benefit equal to 40 percent of compensation, payable annually as a straight life annuity beginning at normal retirement age. Normal retirement age under the plan is 65. The stated interes…
45. Treas. Reg. § 31.3405(c)-1 — Withholding on eligible rollover distributions; questions and answers..
    IRCRegulationsSep 17, 2024
    …on 3405(c), as added by UCA, applies to eligible rollover distributions made on or after January 1, 1993, even if the employee's employment with the employer maintaining the plan terminated before January 1, 1993 and even if the eligible rollover distribution is part of a series of payments that began before January 1,…
46. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998
    …d an accuracy-related penalty under section 6662(a) 1 in the amount of $34,194 for the taxable year 1993. The issues for decision are: (1) Whether petitioner's use of distributions from Keogh and individual retirement accounts (IRA's) to purchase stock which was contributed to an IRA constitutes a tax-free rollover con…
47. 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…
48. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    … • warnings that he was in danger of being penalized. For example, in Mathews v. Commissioner, T.C. Memo. 2005-84, we told petitioner: "Even though the filing of the petition resulted in respondent's concession of the sec. 72(t) additional tax,
49. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    …rwise indicated. All Rule references are to the Tax Court Rules of Practice and (continued...) T.C. Memo. 1998-36 UNITED STATES TAX COURT NEIL M. BAIZER, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21046-94. Filed January 27, 1998. Frederick A. Romero , for petitioner. Clifton B. Cates III , …
50. DOL EBSA (final agency order) — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. NORTHWESTERN INSTITUTE OF PSYCHIATRY
    ERISACourt RulingsJul 26, 1995
    …nior Policy Advisor [ENDNOTES] [1] This letter was mistakenly referred to as being sent on arch 20, 1993 in the ALJ opinion. [2] While NIP's letter was dated June 6, 1990, the enclosed Form 5500 was dated June 7, 1993. In the ALJ opinion, this letter was described as sent on June 20, 1993. [3] The Administrative Law Ju…
51. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
52. DOL Office of Administrative Law Judges — U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. NORTHWESTERN INSTITUTE OF PSYCHIATRY
    ERISACourt RulingsDec 21, 1993
    …S Search Case Status DOL Home > OALJ > ERISA > USDOL, PWBA v. Northwestern Institute of Psychiatry, 1993-RIS-23 (ALJ Dec. 21, 1993) USDOL/OALJ Reporter USDOL, PWBA v. Northwestern Institute of Psychiatry, 1993-RIS-23 (ALJ Dec. 21, 1993) Date: December 21, 1993 Case No.: 93-RIS-23 In the Matter of U.S. DEPARTMENT OF LAB…
53. 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…