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 .
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Further, to broadl…
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 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…
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 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 RulingsSep 25, 1996related by meaning
…iencies............................... 146
C. No Need To Address Other Issues............ 151
- 5 -
MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge
: In seven of these consolidated cases
respondent determined deficiencies in Federal income taxes as
follows:
Taxable
Docket No.
Petitioners
Year
Deficiency
13364-89 B…
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 RulingsNov 13, 1998related by meaning
…A). See, e.g., Clark v. Commissioner
, 101 T.C. 215,
224-225 (1993); Vorwald v. Commissioner
, T.C. Memo. 1997-15;
- 6 -
Hobson v. Commissioner
, T.C. Memo. 1996-272; Grow v.
Commissioner
, T.C. Memo. 1995-594; Wheeler v. Commissioner
, T.C.
Memo. 1993-561. The language of section 72(t) simply does not
differentiate be…
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 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.…
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 RulingsMar 12, 2015related by meaning
Tax, Additional Amounts, and Assessable Penalties".¹°
What these terms have in common is that they refer to amounts that are assessed
8(...continued) 23, 1998, see Internal Revenue Service Restructuring and Reform Act of 1998,
Pub. L. No. 105-206, sec. 3001(c), 112 Stat. at 727, and the taxpayer in that case
anyway bo…
75 FR 53172 — Prohibited Transaction Exemption Procedures; Employee Benefit Plans ERISAProposed Rules (FR)Proposed Aug 30, 2010related by meaning
he same investment manager, and the execution of certain foreign exchange transactions between a plan and a bank or broker-dealer.
Back to Citation
3. Additional information concerning the requirements for obtaining administrative relief under PTE 96-62 (as amended) may be obtained by accessing the complete text of th…
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 RulingsJun 11, 1996related by meaning
…in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20303-94. Filed June 11, 1996.
Janet I. McCurdy
, for petitioners.
Alan…
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 RulingsJan 3, 2017related by meaning
v.
Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo.
2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v.
- 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001).
While we acknowledge and are sympathetic to petitioner's financial straits, we
have no aut…
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 RulingsJan 12, 1998related by meaning
ontrol of the use of the IRA
distributions. We are not persuaded by respondent's argument
that the instant situation falls within the ambit of Aronson because, by virtue of the plea agreement, his consent to the
forfeiture, and his avoidance of a fine or potentially longer
prison sentence, petitioner should be treated …
IRCCourt RulingsMar 31, 1997related by meaning
ble. Zmuda v. Commissioner
, 79
T.C. 714, 727 (1982), affd. 731 F.2d 1417 (9th Cir. 1984).
In this instance, petitioner readily admits that A Atlantic is presently holding his property, and that there is a
- 9 -
7
For the purposes of sec. 72(t), the term "employee" also
refers to participants in individual retirement a…