IRCCourt RulingsAug 6, 1991related by meaning
f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
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 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 RulingsFeb 4, 1998related by meaning
ng warned by the Court
and after having received notice from the Court in a prior case.
6
On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's
position is both frivolous and groundless. Accordingly, we
exercise our discretion and award a penalty t…
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…
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 …
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 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…
IRCCourt RulingsAug 13, 1990related by meaning
…cessitate suppression of evidence obtained after extension obtained); Epstein v. Commissioner, T.C. Memo. 1989-498 (failure to follow procedures set forth in Internal Revenue Manual did not invalidate statutory notice); First Federal Savings & Loan Association of Pittsburgh v. Goldman, 644 F. Supp. 101 (W.D. Pa. 1986) …
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 26, 2017related by meaning
e requirements of the QDRO provisions must be "rigidly observed"
because they "relate to the substance or essence of the statute"). We have con-
- 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help
minimize stress on his soon-to-be ex-wife disabled him from satisfying the
statutor…
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 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 RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
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 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…
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 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…
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 …