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41. T.C. Summary Opinion 2003-91 — Mary L. Coleman-Stephens v. Commissioner
    IRCCourt RulingsJul 16, 2003
    …uce her workday to 4 hours. Petitioner temporarily stopped meeting with Dr. Labovitz after July 31, 1998. Petitioner then reentered the hospital in October 1998 and stayed there for approximately 2 weeks, after which time she began meeting with Dr. Labovitz again. By letter dated December 18, 1998, Dr. Labovitz stated …
42. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
43. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    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…
44. 81 FR 21139 — Amendment to Prohibited Transaction Exemption (PTE) 75-1, Part V, Exemptions From Prohibitions Respecting Certain Classes of Transactions Involving Employee Be…
    ERISAFinal Rules (FR)Apr 8, 2016related by meaning
    under section 4975 of the Code] is hereby transferred to the Secretary of Labor”). Back to Citation 9.  29 CFR 2550.408b-2(e); 26 CFR 54.4975-6(a)(5). Back to Citation 10.   See PTE 86-128, Exemption for Securities Transactions Involving Employee Benefit Plans and Broker-Dealers, 51 FR 41686 (November 18, 1986), as ame…
45. T.C. Memo. 2016-33 — Sally M. Costello v. Commissioner
    IRCCourt RulingsMar 1, 2016related by meaning
    ion provisions allow for the correction of an error made in a closed tax year by extending the limitations period up to one year from the date a - 8 - [*8] final determination is made. Secs. 1311, 1314(b); see Beaudry Motor Co. v. United States, 98 F.3d 1167, 1168 (9th Cir. 1996). Their intent is to take "the profit ou…
46. 101 T.C. 489; 101 T.C. No. 32 — Powell v. Commissioner
    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…
47. T.C. Memo. 1998-321 — Robert J. Hoaglund v. Commissioner
    IRCCourt RulingsSep 9, 1998
    T.C. Memo. 1998-321 UNITED STATES TAX COURT ROBERT J. HOAGLUND, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18418-97. Filed September 9, 1998. Robert J. Hoaglund, pro se. Margaret C. Tinagero , for respondent. MEMORANDUM OPINION JACOBS, Judge : This case is presently before the Court on respo…
48. 97 T.C. 51; 97 T.C. No. 4 — Darby v. Commissioner
    IRCCourt RulingsJul 24, 1991related by meaning
    and sec. 1011A(b)(l) of the Technical and Miscellaneous Revenue Act of 1988 (Pub. L. 100-647, 102 Stat. 3342, 3472), do not affect the instant case.] Sec. 1.72-8. Effect of certain employer contributions with respect to premiums or other consideration paid or contributed by an employee, (a) Contributions in the nature…
49. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    … • warnings that he was in danger of being penalized. For example, in Mathews v. Commissioner, T.C. Memo. 2005-84, we told petitioner: "Even though the filing of the petition resulted in respondent's concession of the sec. 72(t) additional tax,
50. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    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…
51. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004
    …on located in Atlanta, Georgia. Petitioner was the secretary/treasurer of Jocks and Jills, Inc., in 1998 and 1999, and its registered agent in Georgia in 1998 and 1999. On the dates shown supra in table 1 petitioner had a 33.165-percent interest in Jocks and Jills, Inc. There were more than 70 other partners; the next …
52. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000related by meaning
    red all of petitioners’ arguments for contrary holdings; those arguments not discussed herein are irrelevant or without merit. We also have considered respondent’s arguments as to his determinations to the extent necessary to reject or sustain each determination . We also have considered all of respondent’s arguments a…
53. T.C. Memo. 2009-263 — James A. & Linda A. Willhite v. Commissioner
    IRCCourt RulingsNov 18, 2009
    … the finalanalysis, petitioner[s] had no realistic choice ." Murillo v . Commissioner * * * [T .C . Memo . 1998-13 ., affd . without published opinion on other issues 166 F .3d 1201 (2d Cir . 1998)] ., citing Larotonda * * * [v . Commissioner , 89 T .C . 287 (1987)] . Petitioners did exactly what the law, and the IRS, …
54. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    …), affd. without published opinion 578 F.2d 1383 (8th 042 Cir. 1978); Bartley v. Commissioner, T.C.·Memo. 1998-322; Ruben v. Commissioner, T.C. Memo. 1987-277; Downing v. Commissioner, T.C. Memo. 1983-97; Warren v. Commissioner, T.C. Memo. 1982-696; Notter v. Commissioner, T.C. Memo. 1982-96; Cunninghman v. Commissione…
55. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
56. Treas. Reg. § 1.401(a)(4)-11(g)(6) — Additional rules.
    IRCRegulationsMay 18, 2016
    … plan, the accrual rates for all HCEs (determined under the general test of § 1.401(a)(4)-3(c)) for 1998 are less than 1.5 percent of average annual compensation, and the accrual rates for all NHCEs (determined under the general test of § 1.401(a)(4)-3(c)) for 1998 are two percent of average annual compensation. If Emp…
57. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010related by meaning
    …ent,inniaking See Green'v . Commissioner , 507 F .3d 857, 868' (5th Cir . 2007)' - : affg' . T .C . Memo . 2005-250 ;- 10 - Stocks v . Commissioner, 98 .T .C . 1,_ 9 4(1992) "[T]he critical question is, in lieu of what was the settlement amount paid"?, Bagley v . Commissioner , 105 T .C ._ 396, 406 (1995) . ., affd . -…
58. T.C. Memo. 1996-272 — Tommy L. & Patricia A. Hobson v. Commissioner
    IRCCourt RulingsJun 12, 1996related by meaning
    tioner's distribution. Section 72(t) provides: (1) Imposition of additional tax.--If any taxpayer receives any amount from a qualified retirement plan * * *, the taxpayer's tax * * * for the taxable year in which such amount is received shall be increased by an amount equal to 10 percent of the portion of such amount w…
59. PLR 199916023 — Taxation of Employee Annuities (Taxable v. Not Taxable)
    IRCPrivate Letter RulingsApr 23, 1999
    …g = Stock Holding 2 = State A = State B = Year 1 = This letter is in reply to a letter dated May 8, 1998, and supplemental correspondence, regarding the federal income tax consequences of a proposed transaction. Specifically, a ruling is requested that the conversion of a mutual insurance company to a stock insurance c…
60. PLR 200148051 — Roth IRA
    IRCPrivate Letter RulingsNov 30, 2001
    vice issued an underreporter notice to the taxpayer for his 1998 year with the result that the 1998 modified AGI exceeded $100,000. The taxpayer filed an amended return for 1998, seeking a refund of the taxes paid on the Roth IRA conversion because there was a failed conversion. The taxpayer stated that he could not ta…