IRCCourt RulingsJan 23, 2001
spect of the
taxable year 1997.
Petitioners timely filed a joint Federal income tax return
(Form 1040) for 1997. On their return, petitioners reported total income of $79,300, consisting of wages of $79,271 and
taxable interest of $29. Petitioners deducted from total income
the $2,000 amount that had been contributed t…
IRCCourt RulingsDec 13, 2005
…the date the
contract is entered into or construction co mm ences ." S . Rept .
105-33 , at 30-31 ( 1997 ), 1997-4 C .B . (Vol . 2) 1067, 1110 ; H .
Conf . Rept . 105-220 , at 381 (1997), 1997-4 C .B . (Vol . 2) 1457,
1851 ; H . Rept . 105-148 , at 338 (1997), 1997-4 C .B . (Vol . 1) 319,
660 .
- 8 -
Further, to broadl…
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…
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 RulingsNov 25, 2009related by meaning
t affect the tax treatment
- 5
under the Internal, Revenue Code . See sec . 7701(j)(5) ("No
provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the
treatment under this title of the Thrift Savings Fund or any
contribution to, or distribution from, such Fund .…
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…
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…
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 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 …
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…
IRCCourt RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …
IRCCourt RulingsNov 29, 1993related by meaning
aws. As to the precedential value of Memorandum Opinions, see, e.g., Newman v. Commissioner, 68 T.C. 494, 502 n.4 (1977). [Id. at 67; emphasis added.] In light of our restrained articulation in Darby, and particularly its caveat as to a community property situation, we are satisfied that Darby does not compel a decisio…
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 RulingsAug 13, 1990related by meaning
et interest rate for the use of money shall be the higher of the rate on the date of the prohibited transaction or the rate on the date of correction. If a prohibited transaction is not corrected within the taxable period, disqualified persons participating in the prohibited transaction become liable for a second-tier …
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 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…
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 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…