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Go to T.C. Memo. 1997-171 (not yet in the library — opens the official source)
63 documents · 0.24sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-369 — Westchester Plastic Surgical Associates, P.C. v. Commissioner
    IRCCourt RulingsNov 5, 1999related by meaning
    T.C. Memo. 1999-369 UNITED STATES TAX COURT WESTCHESTER PLASTIC SURGICAL ASSOCIATES, P.C., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13073-97R. Filed November 5, 1999. Andrew I. Panken and Robert A. DeVellis , for petitioner. Mark L. Hulse and Catherine R. Chastanet , for respondent. MEMORA…
  2. T.C. Memo. 1997-159 — Robert Charles Fohrmeister v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    ort the 10-percent additional tax, believing that he qualified for the disability exception. Although petitioner failed to qualify under the technical provisions of the Internal Revenue Code and the regulations, we - 13 - do not believe petitioner acted unreasonably or intentionally disregarded the rules and regulation…
  3. 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 …
  4. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    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…
  5. 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 …
  6. T.C. Summary Opinion 2006-184 — William Edward & Patricia Marie Colombell v. Commissioner
    IRCCourt RulingsNov 30, 2006related by meaning
    ted States , 68 Fed. Cl. 177, 188 (2005) (quoting Marsh & McLennan Cos. v. United States , supra , at 1381). Rather, we must apply the language of the relevant provisions, as written. See Commissioner v. Lundy , 516 U.S. 235, 252 (1996) (courts are “bound by the language of the statute as it is written”); Badaracco v. …
  7. T.C. Memo. 2008-28 — Lisa H. Green v. Commissioner
    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…
  8. 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.…
  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. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    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…
  11. 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 …
  12. 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 …
  13. T.C. Memo. 1997-556 — A. C. Green Electrical Contractors, Inc. v. Commissioner
    IRCCourt RulingsDec 22, 1997related by meaning
    T.C. Memo. 1997-556 UNITED STATES TAX COURT A.C. GREEN ELECTRICAL CONTRACTORS, INC., Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8794-95. Filed December 22, 1997. Bruce H. Guttman , for petitioner. Peter J. Gavagan , for respondent. MEMORANDUM OPINION SWIFT, Judge : Respondent determined defi…
  14. 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…
  15. 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 -- $…
  16. 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…
  17. 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…
  18. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    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…
  19. 93 T.C. 449; 93 T.C. No. 36 — American Business Service Corp. v. Commissioner
    IRCCourt RulingsOct 3, 1989related by meaning
    e enjoyment of the recreational activities to petitioner’s permanent staff without running afoul of the restrictions in section 274(e)(5). We so hold. A final note. We hasten to point out that, although we decide as a matter of law that a proper interpretation of section 274(e)(5) does not require in absolute terms tha…
  20. 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 …