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,
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 …
ERISACourt RulingsMar 23, 2001
qualified 1997 IQPA
report. GX 5; RX B.
10. PWBA issued a Notice of Intent to Assess a
Penalty on or about January 14, 2000, reiterating that the 1997 IQPA report was deficient because the scope of the audit was
inappropriately limited,1 and proposing a penalty of $50,000 against
Schneiderman's for its failure to file …
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 …
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…
T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner IRCCourt RulingsMar 5, 2007
…ive record does not show that respondent
took the proceeds on the sale of the Murray’s house in mid-1997
before the Murrays filed their 1996 tax return around Apr. 15,
1997.
the proceeds on the sale of the Murrays’ house in mid-1997, and
petitioner and intervenor filed for bankruptcy in September 1997.
We disagree. Int…
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…
IRCCourt RulingsJan 14, 2002
…x, Inc. ceased operations
by 1989 and did not file a Federal income tax return for the
taxable year 1997.
In 1997, respondent levied petitioner-husband’s IRA held at
Dean Witter Reynolds (Dean Witter) in order to collect the
liability from the section 6672 assessment. The IRA was in
petitioner-husband’s name only, and …
IRCCourt RulingsFeb 22, 1999
…ark L. Hulse and Roberta M. Amos
, for respondent.
OPINION
FOLEY, Judge
: By notices dated June 25, 1997, respondent
determined deficiencies in, and an addition to, petitioners'
Federal excise taxes as follows:
Gideon L. Medina
Excise Taxes
Addition to Tax
Year
Sec. 4975(a)
Sec. 4975(b)
Sec. 6651(a)(1)
1991 $2,685 -- $…
IRCCourt RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…
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…
122 T.C. No. 5 — Estate of John W. Clause, Deceased; Thomas Y. Clause, Personal Representative v. Commissioner IRCCourt RulingsFeb 9, 2004
, 1997. The second tax
return had attached a statement of election pursuant to section
1042 predated to March 4, 1997, a statement of consent from the company consenting to the application of sections 4978 and 4979A
predated to March 4, 1997, and a statement of petitioner’s
purchase of qualified replacement property pr…
IRCCourt RulingsAug 24, 1995related by meaning
section 1041. See Balding v. Commissioner, 98 T.C. 368 (1992).
In order to implement the views expressed herein,
An appropriate order will be issued. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules o…
IRCCourt RulingsJun 11, 1996related by meaning
g, we give effect to the
plain meaning of the words used therein and sustain respondent's
determination that petitioners are liable for the 10-percent additional tax under section 72(t).
We have considered petitioners' remaining arguments and find
them unpersuasive.
3. Conclusion
In order to give effect to our disposit…
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 RulingsJun 12, 1996related by meaning
tioner's
distribution.
Section 72(t) provides:
(1) Imposition of additional tax.--If any taxpayer
receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in
which such amount is received shall be increased by an
amount equal to 10 percent of the portion of such
amount w…
PBGCPBGC Opinion LettersDec 29, 1997
Pension Benefit Guaranty Corporation
97-2
December 29, 1997
RE FE RE NC E:
[*1] 402 1(b)(1 3) Plans C overed . Professional Se rvice Em ployer P lans
OP INI ON :
I
wri te i n res ponse t o your reque st for a recon side rat ion of the Pensi on
Be nefit Gu aranty
Corporat ion' s ("PBGC")
initial dete rmina tion with
re …
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsMay 29, 1997related by meaning
…e year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-244
UNITED STATES TAX COURT
O.H. TOLLEY, JR. AND BETTY TOLLEY, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11407-95. Filed May 29, 1997.
William H. Scheil, Jr.
, for petitioners.
Ve…
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.…