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…
IRCCourt RulingsJun 4, 1997
…$164,998, $230,152, $255,993 was reported by Allstate
on Forms W-2 as wages paid to petitioners for 1989, 1990, and 1991, respectively. Allstate withheld income and Social Security
taxes from petitioners' wages. Petitioners reported these
amounts as wages on their 1989, 1990, and 1991 joint Federal
income tax returns (…
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 RulingsApr 2, 2020related by meaning
…
T.C. 85, 101 (2004); Keller v. Commissioner, 568 F.3d 710, 718 (9th Cir. 2009),
aff'g in part T.C. Memo. 2006-166, and aff'g in part, vacating in part decisions in
related cases. Goldberg resided in Illinois when he filed his petition. Therefore
our decision will not be appealable to the First, Eighth, or Ninth Circui…
IRCCourt RulingsNov 10, 1998
…e the
following deposits to and withdrawals from the IRA account:
Date
Deposits
Withdrawals
Dec. 8, 1989 $50
Dec. 15, 1989 50
Dec. 22, 1989 50
Dec. 29, 1989 50
Jan. 5, 1990 50
Apr. 18, 1990 1,100
May 4, 1991 $1,400
May 22, 1991 2,000
In 1992, petitioner made the following withdrawals from the IRA
account:
IRCCourt RulingsMay 23, 1996
…ase involves only petitioner's CSRS annuity.
5
These totals consisted of the following items:
Payor
1989
1990
1991
PERS $3,649.32 $3,748.32 $3,847.32
U.S. Army 13,939.68 14,736.99 15,581.40
OPM 11,447.84 13,680.00 14,412.00
Total $29,036.84 $32,165.31 $33,840.72
During the year 1989, after having his annuity distributi…
IRCCourt RulingsDec 19, 2000related by meaning
T.C. Memo. 2000-384
UNITED STATES TAX COURT
ROBERT W. AND VIVIAN TOAN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17168-95. Filed December 19, 2000.
Robert W. Toan and Vivian Toan, pro sese.
Paul L. Darcy
, for respondent.
MEMORANDUM OPINION
LARO, Judge
: This case was submitted to the Cour…
IRCCourt RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…
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 RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
IRCCourt RulingsJun 25, 2012related by meaning
other grounds, and
remanding T.C. Memo. 1991-144; Corson v. Commissioner, 123 T.C. at 206;
Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430, 442 (1997). - 9 -
II. Administrative Costs
The administrative costs at issue are costs that petitioner incurred from the .
time respondent issued the notice of deficiency up to the …
IRCCourt RulingsAug 13, 1990related by meaning
…cessitate suppression of evidence obtained after extension obtained); Epstein v. Commissioner, T.C. Memo. 1989-498 (failure to follow procedures set forth in Internal Revenue Manual did not invalidate statutory notice); First Federal Savings & Loan Association of Pittsburgh v. Goldman, 644 F. Supp. 101 (W.D. Pa. 1986) …
IRCCourt RulingsApr 11, 2012related by meaning
Notice 95-34 the IRS provided guidance on the tax problems raised
by certain trust arrangements in seeking to qualify for jexemption from section 419. Furthermore, before any of the years at issue, this Court issued Neonatology
Assocs., P.A. v. Commissioner, 115 T.C. 43. We therefore conclude that there
was not substan…
IRCCourt RulingsNov 30, 2006related by meaning
…ur jurisdiction to grant
equitable relief is limited. Woods v. Commissioner
, 92 T.C. 776,
784-787 (1989); Estate of Rosenberg v. Commissioner
, 73 T.C.
1014, 1017-1018 (1980). Accordingly, we must sustain
respondent’s determination.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect our disp…