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Go to T.C. Memo. 1997-126 (not yet in the library — opens the official source)
65 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2014-106 — Whistleblower 10949-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
  2. 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…
  3. 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…
  4. DOL Office of Administrative Law Judges — USDOL, EBSA v. SCHNEIDERMAN'S FURNITURE, INC.
    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 …
  5. 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…
  6. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    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…
  7. 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…
  8. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019related by meaning
    DRC T.C. Memo. 2019-67 UNITED STATES TAX COURT MARIA SHENORAH MCCREE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10129-14L. Filed June 6, 2019. Maria Shenorah McCree, pro se. Moenika N. Coleman, Linda L. Wong, Michael S. Navarro, and Cindy L. Wofford, for respondent. MEMORANDUM FINDINGS OF FA…
  9. 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…
  10. T.C. Summary Opinion 2012-59 — Mary Ellen Macdonald v. Commissioner
    IRCCourt RulingsJun 25, 2012related by meaning
    other grounds, and remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206; Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 - II. Administrative Costs The administrative costs at issue are costs that petitioner incurred from the . time respondent issued the notice of deficiency up to the …
  11. T.C. Summary Opinion 2002-2 — William J. Phillips, Jr. & Matrona A. Phillips v. Commissioner
    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 …
  12. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    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 -- $…
  13. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    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…
  14. 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…
  15. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
  16. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020related by meaning
    …tion...................................... 125 2. Events .......................................... 126 3. Analysis and holding............................... 131 BB. Intermediary period: January 4-6, 2011 . . . . . . . . . . . . . . . . . . . . . 133 CC. Period 18: January 7-10, 2011 . . . . . . . . . . . . . . . . . …
  17. PBGC Op. Ltr. 1997-2 — Coverage, Professional service employer plan
    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 …
  18. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  19. 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…
  20. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ues in the instant case. Consequently, respondent’s objections are sustained, and the reports will not be received in evidence. Validity of Regulation Treasury regulations are not to be rejected unless they are unreasonable and plainly inconsistent with the revenue statutes. Rotenberry v. Commissioner, 847 F.2d 229 (5t…