IRCCourt RulingsOct 19, 2010related by meaning
payer alleged his civil rights
had been violated in the underlying divorce proceedings).
The Court recognizes that petitioner 'does not agree with the Texas State court ruling regarding his child support obligations
and subsequent garnishment. But we cannot address those
allegations, and petitioner 'has not shown a bas…
IRCCourt RulingsJul 12, 2005
nuary 2 payment as income for 2001.
In a statement dated January 16, 2001, USAA informed
petitioner that she had a vested balance of $11,929.32 and an outstanding loan of $10,480.27 in her USAA SIP account as of that
date. Petitioner was informed that she had to pay her
outstanding loan balance by April 17, 2001, or it…
IRCCourt RulingsOct 21, 2003related by meaning
1
Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year at issue.
T.C. Summary Opinion 2003-157
UNITED STATES TAX COURT
DARRELL R. FULCHER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14140-01S. Filed October 21, 2003.
Darrell R. Ful…
IRCCourt RulingsJun 13, 2017related by meaning
JRN
T.C. Memo. 2017-112
UNITED STATES TAX COURT
WHISTLEBLOWER 19860-15W, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19860-15W. Filed June 13, 2017.
Sealed,¹ for petitioner.
Ashley M. Bender and Richard L. Hatfield, for respondent.
MEMORANDUM OPINION
KERRIGAN, Judge: This case is before the Co…
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…
IRCCourt RulingsJun 6, 2019related by meaning
DRC
T.C. Memo. 2019-67
UNITED STATES TAX COURT
MARIA SHENORAH MCCREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10129-14L. Filed June 6, 2019.
Maria Shenorah McCree, pro se.
Moenika N. Coleman, Linda L. Wong, Michael S. Navarro, and Cindy L.
Wofford, for respondent.
MEMORANDUM FINDINGS OF FA…
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…
IRCCourt RulingsJun 18, 1999related by meaning
1402(a). We therefore simply sustain
respondent's determination as respondent did not assert an
increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally
imposed on IRA distributions made before the taxpayer reaches age
59-1/2. See sec. 72(t). In that regard,…
IRCRegulationsDec 30, 2016
the remaining visits during 2001. Example 4.(i) A group health plan has a $250 annual deductible per covered individual. The plan provides that if the deductible is not satisfied in a particular year, expenses incurred during October through December of that year are credited toward satisfaction of the deductible in th…
IRCRegulationsDec 30, 2016
until the current collective bargaining agreement expires, on June 30, 2001, and then X stops making contributions to M. X's employees (and their spouses and dependent children) lose coverage under M effective July 1, 2001. X does not enter into another collective bargaining agreement covering the class of employees co…
IRCCourt RulingsSep 17, 2026related by meaning
n effect at all relevant times, regulation references are
to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure.
Served 09/17/26
2
[* 2 ] there were no changes in the IRS approach to the issue after review
of…
IRCPrivate Letter RulingsMay 10, 2002
Internal Revenue Service
Number: 200219002
Release Date: 5/10/2001
Index Number: 419.00-00 419.14-00
4976.00-00 4976.01-00
Department of the Treasury
Washington, DC 20224
Person to Contact:
Telephone Number:
Refer Reply To:
CC:TEGE:EB:HW:PLR-125981-00
Date:
09/28/2001
LEGEND:
Taxpayer =
Trust=
Council =
Holding Company…
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
PLR 200205007 — Deferred Compensation Plans of State and Local Governments and Tax Exempt Organizations IRCPrivate Letter RulingsFeb 1, 2002
…le.
This ruling is directed only to X and applies only to the plan and trust submitted
on April 11, 2001, as revised by amendments submitted on September 25, 2001 and
October 19, 2001. Section 6110(k)(3) of the Code provides that it may not be used or
cited as precedent.
Temporary or final regulations pertaining to one…
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…
IRCCourt RulingsAug 4, 2005
of the distribution was
used to pay qualified higher education expenses in the taxable
year 2001, the issue is whether petitioners are subject to the 10-percent additional tax under section 72(t)(1) on the remaining
$17,982.99. Petitioners resided in Liberty Township, Ohio, at
the time the petition was filed.
Backgrou…
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…
IRCCourt RulingsAug 1, 2005
…able portion of his
distribution check. In response, Americo sent petitioner a
letter, dated May 9, 2001, requesting petitioner to: (1) Return
the policy contract or submit written acknowledgment that the
policy had been lost or destroyed, and (2) submit written
acknowledgment of the reason or eligibility for a direct
…
IRCCourt RulingsSep 26, 2001related by meaning
… to the Tax Court Rules of Practice and Procedure,
unless otherwise indicated.
T.C. Summary Opinion 2001-158
UNITED STATES TAX COURT
MAJID NAEMI, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8339-00S. Filed September 26, 2001.
Majid Naemi, pro se.
Michele A. Yates
, for respondent.
DEAN, Speci…
IRCCourt RulingsJun 6, 2005
…as filed. Petitioners, Victor A. and Esther Suarez, are husband and
wife. During the year in issue (2001), they were homeowners of
property at 4934 Raffaele Drive, in Sierra Vista, Arizona. In
2001, Victor A. Suarez (hereinafter petitioner) withdrew $33,590
1
from his Individual Retirement Account (IRA). He received th…