IRCCourt RulingsApr 18, 1996
… used for business purposes in 1989.
During the year in issue, petitioners owned at least 4 cars:
A 1987 Suzuki Samurai, a 1987 Cadillac Fleetwood, a 1987 Ford
Aerostar, and a 1984 Dodge Colt. Petitioner claims he used the
Cadillac 82 percent of the time for business and that the other
automobiles were used for persona…
IRCCourt RulingsDec 7, 1993
…utstanding. See Westoak Realty & Inv. Co. v. Commissioner, 999 F.2d 308 (8th Cir. 1993), affg. T.C. Memo. 1992-171; Leib v. Commissioner, 88 T.C. 1474, 1486-1487 (1987).
IRCCourt RulingsApr 2, 2024related by meaning
, 1485 (2021)
(“ [A]s this Court has long made plain, pleas of administrative
inconvenience and self-serving regulations never ‘justify departing from the statute’s clear text. ’” (quoting Pereira v. Sessions, 138 S. Ct. 2105,
2118 (2018)); Chevron , 467 U.S. at 842– 43 (“If the intent of Congress is
clear, that is the…
IRCCourt RulingsMar 20, 1997
…Bail Bonds By Marvin Nelson, Inc. v. Commissioner
,
820 F.2d 1543, 1549 (9th Cir. 1987), affg. T.C. Memo. 1986-23),
affg. T.C. Memo. 1987-628. This two-part test, however, is not
- 30 -
IRCCourt RulingsJun 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
IRCCourt RulingsMay 13, 1999
…t under substantially identical circumstances. See
Howard E. Clendenen, Inc. v. Commissioner
, T.C. Memo. 1998-318;
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd. per
curiam without published opinion 89 F.3d 841 (8th Cir. 1996).
8
We rejected the same arguments presented herein and concluded
that respon…
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regulations or withdrawn.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case have been neither replaced nor withdrawn, so we rely on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.…
IRCRegulationsSep 9, 2016
…December 31, 1988. (i) The average value as of December 31, 1988, is computed as follows: 1986 1986 1987 1987 1988 1988 Fair market value: Jan. 1 $150,000 $196,500 $238,000 Contributions $65,000 $62,000 $66,000 Benefit payments (22,000) (24,000) (25,000) Expenses (6,500) (7,000) (7,500) Interest and dividends 8,000 44,…
ERISARegulationsJan 1, 2017
…l, this section is effective for purposes of identifying the assets of a plan on or after March 13, 1987. Except as a defense, this section shall not apply to investments in an entity in existence on March 13, 1987, if no plan subject to title I of the Act or plan described in section 4975(e)(1) of the Code (other than…
IRCCourt RulingsSep 30, 2003related by meaning
…he list
of specific exceptions to tax set forth in section 72(t)(2).
Swihart v. Commissioner
, T.C. Memo. 1998-407. Moreover, unlike
petitioners in the present case, the taxpayers in Larotonda
never
- 8 -
received the funds and had no opportunity to avoid the 10-percent
premature distribution penalty under former secti…
ERISACourt RulingsAug 25, 1995
…tion Board of Managers, Respondent Taggart signed a conflict of interest statement, dated March 17,
1987. (Stip. Fact 10; J-Exs. 26-27).
13. On or about September 17, 1987, the TPEHA Board of
anagers passed a resolution approving a merger between TPEHA and
the Missouri Pacific Employees' Hospital Association. (Stip.
Fa…