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41. 106 T.C. No. 3 — James H. & Josephine A. Swanson v. Commissioner
    IRCCourt RulingsFeb 14, 1996
    …pondent conceded the Algonquin property issue in a settlement agreement entered into on January 24, 1994. The parties agreed at that time to a total deficiency of $11,372.40, which reflected an amount conceded by petitioners in their petition as capital gain inadvertently omitted from their 1988 Federal income tax. A s…
42. 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 .
43. 85 FR 55219 — Fiduciary Duties Regarding Proxy Voting and Shareholder Rights
    ERISAProposed Rules (FR)Proposed Sep 4, 2020
    …t of Labor, Transcript of Press Conference on Corporate Activist Role in Pension Planning (July 28, 1994), at 15-16 (then-Secretary Robert Reich stating that IB 94-2 “makes very clear that . . . pension fund managers, trustees, [and] fiduciaries have an obligation to vote proxies” unless the costs “substantially outwei…
44. 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…
45. 84 FR 53579 — Real Estate Appraisals
    IRCFinal Rules (FR)Oct 8, 2019
    etermine changes in house prices since 1994. The agencies also analyzed general measures of inflation by reviewing the Consumer Price Index (CPI).[35] A residential property that sold for $250,000 as of June 30, 1994, would be expected to sell in March 2019 for $643,750 according to the Case-Shiller Index and $621,448 …
46. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
47. T.C. Memo. 1998-407 — Stephen Neal Swihart v. Commissioner
    IRCCourt RulingsNov 13, 1998
    …he year in issue petitioner worked for Key Trucking, Inc. (Key), as a salesman. At the beginning of 1994 petitioner was paid a salary by Key. In late January or early February, Key ceased paying petitioner a salary, and, instead, - 3 - paid him commissions on his sales. In August 1994, Key resumed paying petitioner a s…
48. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997related by meaning
    ng bank at the end of 1992. Based on our examination of the entire record before us, we find that petitioners have failed to show that they acted with reasonable cause and in good faith, or that they otherwise exercised due care or made a reasonable attempt to comply with the Code, when they claimed the 1992 and 1993 d…
49. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
    IRCCourt RulingsDec 20, 2001
    ant to that addendum, on January 12, 1994, Burien Nissan canceled Mr. Buchner’s 5,880 shares of stock as well as the 61,200 remaining Johnston shares. As a result of the addendum to the May 25, 1990 stock purchase agreement, as of January 12, 1994, the ownership of Burien Nissan stock was as follows: Stockholder Number…
50. T.C. Memo. 1997-8 — Gary Benton & Karen Ruth Logsdon v. Commissioner
    IRCCourt RulingsJan 6, 1997related by meaning
    T.C. Memo. 1997-8 UNITED STATES TAX COURT GARY BENTON LOGSDON AND KAREN RUTH LOGSDON, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10919-94. Filed January 6, 1997. Gary Benton Logsdon and Karen Ruth Logsdon, pro se. Kathey I. Shaw , for respondent. MEMORANDUM OPINION HAMBLEN, Judge : Responde…
51. T.C. Memo. 1998-379 — Dale Reid Edmonds v. Commissioner
    IRCCourt RulingsOct 20, 1998
    …spondent contends that petitioner did not make a qualified retirement contribution to an IRA during 1994. In the - 6 - alternative, respondent argues that, even if petitioner did make a qualified IRA contribution during 1994, he is precluded by the limitations of section 219(g) from deducting such contribution. Petitio…
52. 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…
53. 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.…
54. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
55. T.C. Memo. 2000-78 — Philip Lewis Hart v. Commissioner
    IRCCourt RulingsMar 7, 2000
    …s liable for accuracy-related penalties under section 6662(a) for the underpayment of taxes for the 1994 and 1995 taxable years; and (6) whether a penalty should be awarded to the United States under section 6673. For clarity and simplicity, we have combined the findings of fact and conclusions of law. Some of the fact…
56. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
57. Treas. Reg. § 1.401(a)(4)-13(c)(6) — Effective dates and fresh-start rules.
    IRCRegulationsMay 18, 2016
    …lied by the employee's years of service for Employer X up to 40. (b) For plan years beginning after 1994, Employer X amends the plan formula to provide a normal retirement benefit of 0.75 percent of average annual compensation up to covered compensation multiplied by the employee's total years of service for Employer X…
58. 111 T.C. No. 20 — Dona Elizabeth Conway v. Commissioner
    IRCCourt RulingsDec 30, 1998
    e home. In 1994, petitioner paid a $10,000 consulting fee relating to a family business plan and to the acquisition and the sale of personal property. In 1994, petitioner received $5,149 as a distribution from an individual retirement account (IRA) that petitioner maintained at Great-West Life & Annuity Insurance Co. (…
59. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
60. T.C. Memo. 1998-36 — Neil M. Baizer v. Commissioner
    IRCCourt RulingsJan 27, 1998related by meaning
    2,803.75 12/31/88 11,215 -- -- $560.75 2,803.75 12/31/89 11,215 -- -- -- 2,803.75 12/31/90 11,215 -- -- -- 2,803.75 12/31/91 11,215 -- -- -- 2,803.75 12/31/92 11,215 -- -- -- 2,803.75 12/31/93 11,215 -- -- -- 2,803.75 08/18/94 -- $224,298 -- -- -- This case involves the question of whether an assignment of accounts re…