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Go to T.C. Memo. 1996-154 (not yet in the library — opens the official source)
72 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2006-136 — Larry J. & Catherine E. France v. Commissioner
    IRCCourt RulingsAug 30, 2006
    …sion and an anxiety disorder. Petitioner’s difficulties with his supervisor continued until January 1996. At that time, petitioner’s mental health had deteriorated to the point that his physician recommended he stop working at the Animal Control Division. In accordance with this recommendation, petitioner left the Anim…
  2. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    …nial of equitable relief under the last sentence of section 66(c). Beck - 9 - v. Commissioner, T.C. Memo 2001-198. Here, we review respondent's denial of equitable relief under section 66(c) for abuse of discretion. Id ; see also Fernandez v. Commissioner, 114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
  3. T.C. Summary Opinion 2001-8 — Peter Spuler, Jr. v. Commissioner
    IRCCourt RulingsFeb 2, 2001
    property under the will. Petitioner received automatic extensions to file his 1995 and 1996 Federal income tax returns. The due date of the 1995 - 5 - and 1996 returns as extended were August 15, 1996, and August 15, 1997, respectively. Petitioner’s 1995 and 1996 tax returns were received by respondent on August 21, 19…
  4. 122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 9, 2004
    …9, 2004. P, prior to his death, sold all of his shares in C to C’s employee stock ownership plan in 1996. P purchased qualified replacement property with most of the proceeds from the sale within a year of the sale. P’s 1996 original Federal tax return was filed timely (i.e., on or before Apr. 15, 1997) and did not rep…
  5. 81 FR 47534 — Proposed Revision of Annual Information Return/Reports
    ERISAProposed Rules (FR)Proposed Jul 21, 2016
    …established well before the enactment of the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, 110 Stat. 1936 (Aug. 21, 1996); Title I of the Genetic Information Nondiscrimination Act of 2008, Public Law 110-233, 122 Stat. 881 (May 21, 2008); the Mental Health Parity Act of 1996, Public L…
  6. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  7. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …), affd. without published opinion 578 F.2d 1383 (8th 042 Cir. 1978); Bartley v. Commissioner, T.C.·Memo. 1998-322; Ruben v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner, T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696; Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v. Commissione…
  8. 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…
  9. 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…
  10. T.C. Summary Opinion 2003-99 — Barney K. & Lindy W. Huang v. Commissioner
    IRCCourt RulingsJul 23, 2003
    …terest Expense Petitioners claimed an itemized deduction for mortgage interest expense of $8,732 in 1996. Respondent decreased this deduction, allowing a deduction of only $3,732. Mortgage interest expense generally is deductible by individual taxpayers, subject to various limitations not relevant here. Sec. 163(a), (h…
  11. 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…
  12. 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…
  13. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CURRENT DEVELOPMENT CORPORATION
    ERISACourt RulingsFeb 22, 2000
    … October, 1986, and represented approximately 50% of the total assets of the two Plans. On July 26, 1996, ChiRO informed the trustees of the two Plans that its retention of the Westmont Property constituted a violation of § 404 (a) (1) (B) of ERISA. PWBA also informed the Administrator that there were violations for th…
  14. 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…
  15. 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 …
  16. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004
    …fter sometimes referred to collectively as the Borrowers. Table 1 Loan Date Borrower Amount May 29, 1996 J & J Charlotte $100,000 June 7, 1996 J & J Charlotte 100,000 June 12, 1996 J & J Charlotte 75,000 July 8, 1996 J & J Charlotte 25, 000 Sept. 9, 1996 J & J Charlotte . 25,000 May 20, 1997 Eagle Bluff 50,000 Sept. 2,…
  17. 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…
  18. T.C. Summary Opinion 2008-30 — Jay Andrew Reindl v. Commissioner
    IRCCourt RulingsMar 13, 2008
    …dship .' Arnold v . Commissioner , 111 T .C . 250 , 255 (1998) ; Thompson v . Commissioner , T .C . Memo . 2007-327 ; Cole v . Commissioner , T .C . Memo . 2006-44 ; Gallagher v . Commissioner , T .C . Memo . 2001-34 ; Deal v . Commissioner , T .C . Memo . 1999-352 ; Duffy v . Commissioner , T .C . Memo . 1996-556 ; Pu…
  19. T.C. Memo. 1996-292 — Galen J. Smith v. Commissioner
    IRCCourt RulingsJun 24, 1996
    … the years at issue, all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1996-292 UNITED STATES TAX COURT GALEN J. SMITH, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8945-95. Filed June 24, 1996. Galen J. Smith, pro se. Pamelya P. Herndon , for respondent. MEM…
  20. 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…