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…
ERISACourt RulingsOct 14, 1999
…ther stated that, at the time, Comgraphix had engaged the Lauterbach accounting firm to
perform the 1996 audit, but shortly thereafter, Ben Marmande, CFO
of Racom, told Comgraphix representatives that he had consulted
with an ERISA attorney and had been advised that, under the
circumstances, the annual report could be …
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…
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…
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…
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…
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…
IRCCourt RulingsMar 12, 2015related by meaning
Tax, Additional Amounts, and Assessable Penalties".¹°
What these terms have in common is that they refer to amounts that are assessed
8(...continued) 23, 1998, see Internal Revenue Service Restructuring and Reform Act of 1998,
Pub. L. No. 105-206, sec. 3001(c), 112 Stat. at 727, and the taxpayer in that case
anyway bo…
IRCCourt RulingsMay 29, 1997related by meaning
…
prior years. Easter v. Commissioner
, 338 F.2d 968, 969-970 (4th
Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v.
Commissioner
, 55 T.C. 28, 32 (1970). We reject petitioners’
argument that an exception to this rule applies to disputes
involving $10,000 or less.
To reflect the foregoing,
Decision will be entere…
Rev. Rul. 2006-38 — Prohibited transactions; first tier excise tax calculations. This ruling describes how the amount involved is calculated with respect to the section 4975 prohi… IRCRevenue RulingsJul 17, 2006related by meaning
hibited transaction excise tax if an employer does not timely pay elective deferrals to a qualified plan.
ADMINISTRATIVE
Notice 2006-63 Notice 2006-63 This notice requests comments for developing record retention standards, including recordkeeping limitation programs, for tax-exempt bond issues. In particular, the noti…
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,…
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…
IRCCourt RulingsSep 18, 1996
…t, the Transfer Refund was not a
qualified total distribution. See Wittstadt v. Commissioner
,
T.C. Memo. 1995-492, Humberson v. Commissioner
, T.C. Memo. 1995470; Pumphrey v. Commissioner
, T.C. Memo 1995-469; Dorsey v.
Commissioner
, T.C. Memo. 1995-97, affd. without published opinion
91 F.3d 129 (4th Cir. 1996); Hyl…
IRCCourt RulingsFeb 12, 2008related by meaning
oner ,
T .C . Memo . 2004-125 .
- 6 -
Petitioner has not argued, and she has failed to
demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right .
Consequently, we must uphold TRHCA section 408 if it bears a
rational relationship to a legitimate govern…
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…
T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am… IRCTreasury DecisionsAug 28, 2006related by meaning
n the information elicited on those line items, as well as the rest of the form, in their books and records.
Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
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…
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…
IRCPrivate Letter RulingsAug 27, 1999related by meaning
…Number: 199934002
Release Date: 8/27/1999
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Taxpayer's Name:
Taxpayer's Address:
Taxpayer's Ident. No.:
Taxable Years at Issue:
Date of Conference:
Legend
:
Taxpayer =
Plan =
Trust Agreement =
ISSUES
:
(1) Whether, under the rules of section 461 of the …
IRCCourt RulingsMar 7, 2000
…not have
jurisdiction over the section 6654 additions to tax for 1995.
Fujita v. Commissioner, T.C. Memo. 1999-164.
We now consider whether petitioner is liable for the
addition to tax under section 6654 for the .failure to pay
estimated taxes for 1996. Section 6654(c) imposes a requirement
that estimated taxes be paid…