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41. T.C. Summary Opinion 2004-29 — Howard T. Owens, Jr. & Ann E. Owens v. Commissioner
    IRCCourt RulingsMar 15, 2004
    …nd Ann E. Owens, husband and wife, were born on July 20, 1934, and March 29, 1941, respectively. In 1999, petitioners owned multiple IRA accounts, including a Fidelity Investments Traditional IRA in the name of Howard T. Owens, Jr., and a Fidelity Investments Traditional IRA in the name of Ann E. Owens. As of early May…
42. 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…
43. T.C. Summary Opinion 2005-108 — Magellean Askew, Jr. v. Commissioner
    IRCCourt RulingsAug 1, 2005
    …stified at trial, however, that he received this amount in December 1998. The check, dated June 14, 1999, clearly contradicts petitioner’s assertion. 6 Petitioner presented no evidence of the latter two amounts that he claimed to have received from Americo in 1999. 1. Did petitioner receive the distributions at issue i…
44. DOL Office of Administrative Law Judges — UNITED STATES DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION v. CURRENT DEVELOPMENT CORPORATION
    ERISACourt RulingsFeb 22, 2000
    …he matter, and conclude that he did deposit the check in the said mailbox on Thursday, December 31, 1999, at on or about 4:30 p.m.; that it was not picked-up on that date, and that, due to the intervening New Year' s holiday on Friday, January 1, 1999, and the weekend of January 2 and 3, 1999, the pick-up was not made …
45. 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…
46. DOL Office of Administrative Law Judges — USDOL v. COMPGRAPHIX, INC
    ERISACourt RulingsOct 14, 1999
    …partment of Labor Office of Administrative Law Judges Heritage Plaza Bldg. - Suite 530 111 Veterans Memorial Blvd etairie, LA 70005 (504) 589-6201 (504) 589-6268 (FAX) DATE: October 14, 1999 CASE NO.: 1999-RIS-53 In the Matter of U.S. DEPARTMENT OF LABOR, PENSION AND WELFARE BENEFITS ADMINISTRATION, Complainant v. COMP…
47. T.C. Memo. 2010-146 — Peggy Ann Sears v. Commissioner
    IRCCourt RulingsJul 6, 2010
    …cord establishes that at the ;en d 9853 had a f Februar y zero balance, nbut .at ,the end- of March,1999 the tota l asset value of .account No . petitioner did notnotice half oflits,value ;because 9853 was ; $451, 268 .56 . Even i f that account No . 7189 .lost more than , of : the, : March 1999, transfer, = at, . some…
48. T.C. Memo. 2004-260 — Joseph R. Rollins v. Commissioner
    IRCCourt RulingsNov 15, 2004
    e Bluff was not able to make the payments. All $35,000 of these 1999 principal payments were treated as petitioner's additional equity in Eagle Bluff. Petitioner fully intended he would receive the funds back from his equity when Eagle Bluff was sold. - 9 - All of the principal of the Plan's loan to Eagle Bluff has bee…
49. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    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…
50. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsAug 25, 1997related by meaning
    motion for costs was filed out of time and should be "dismissed" for that reason. We reject respondent's contention and do not consider it further. 12 Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, sec. 6239(a), 102 Stat. 3342, 3743-3746 is generally applicable to proceedings commenced after …
51. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
52. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    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 …
53. T.C. Summary Opinion 2003-157 — Darrell R. Fulcher v. Commissioner
    IRCCourt RulingsOct 21, 2003
    …t the taxable amount of the $5,000 distribution was $4,700.47. On his Federal income tax return for 1999, petitioner included $8,643.80 as income, representing the taxable distributions from the two plans. In the notice of deficiency, respondent determined that petitioner was liable for the additional tax under section…
54. 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…
55. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014
    …first nonallocation year with respect to an employee stock ownership plan. According to petitioner, 1999, not 2005, is the first nonallocation year with respect to the ESOP in question. In support of that position, petitioner asserts: C. Assuming An Excise Tax Could Be Imposed Merely By Holding [i.e., owning] Shares, T…
56. 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…
57. 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. …
58. 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…
59. 75 FR 38700 — Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirements; Disclosure Requirements With Respect to Prohibited Tax Shelter Transac…
    IRCFinal Rules (FR)Jul 6, 2010
    …x purposes. (iii) Under X's established cash basis method of accounting, any net income received in 1999 and attributable to the LILO transaction is allocated to X's December 31, 1999, tax year for purposes of section 4965. The $14M fee received in 1999, and which constitutes proceeds of the transaction, is likewise al…
60. 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 …