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61. T.C. Memo. 1995-492 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    IRCCourt RulingsOct 11, 1995related by meaning
    …ble for the 10-percent additional tax imposed by section 72(t). See O'Connor v. Commissioner , T.C. Memo. 1994-170; Wheeler v. Commissioner , T.C. Memo. 1993-561; cf. Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissioner , T.C. Memo. 1995-93. III. Excise Tax Issues Finally, we turn to respondent's excise t…
62. 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…
63. 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…
64. 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…
65. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002
    …delphia, Pennsylvania, on the date the petition was filed in this case. From January through May of 1998, petitioner was employed by the U.S. Defense Finance and Accounting Service. She earned $32,265 in this position, and was covered by her employer’s pension plan during that time. In May 1998, petitioner’s employment…
66. T.D. 9321 — Final regulations set forth guidance on the application of section 409A to nonqualified deferred compensation plans. The regulations provide a definition of a …
    IRCTreasury DecisionsMay 7, 2007related by meaning
    INCOME TAX Rev. Rul. 2007-29 Rev. Rul. 2007-29 Federal rates; adjusted federal rates; adjusted federal long-term rate and the long-term exempt rate. For purposes of sections 382, 642, 1274, 1288, and other sections of the Code, tables set forth the rates for May 2007. Announcement 2007-44 Announcement 2007-44 This anno…
67. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    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,…
68. 134 T.C. No. 6 — Karl L. & Deborah Matthies v. Commissioner
    IRCCourt RulingsFeb 22, 2010related by meaning
    Print 1982) . Sec . 7702 was enacted in 1984 as part of the Deficit Reduction . Act of 1984, Pub . L . 98-369, sec . 221(a), 98 Stat . 767 . Although these statutory amendments . postdate the promulgation of the applicable regulations in 1956, for the reasons . discussed supra we believe that the cross-reference to se…
69. T.C. Summary Opinion 2002-14 — Armando Vega v. Commissioner
    IRCCourt RulingsFeb 15, 2002
    …tion of these issues into the IRA. A statement from Merrill Lynch for the period ending October 31, 1998, however, clearly shows that the distribution had been deposited into the CMA. During 1998, petitioner had a savings account with Hibernia National Bank. That account generated interest income of $117 that petitione…
70. T.C. Memo. 2004-217 — Margie E. Robertson v. Commissioner
    IRCCourt RulingsSep 27, 2004related by meaning
    eduction relating to the note. She also contends that in 1998, the first lien holder attempted to foreclose on the property, and that she attempted to collect on the note in that year. The note is a bona fide debt and became due in 1998 when Ms. Moore died. Petitioner, however, claimed a deduction for the unpaid debt o…
71. T.C. Summary Opinion 2001-178 — Dennis J. Lawless v. Commissioner
    IRCCourt RulingsNov 28, 2001
    …an the amount shown on the taxpayer’s return. Sec. 301.6211-1(f), Proced. & Admin. Regs. On July 6, 1998, respondent abated the entire $7,219 assessment that he had previously made on May 25, 1998. Although the record is silent as to why respondent made this abatement, the fact that it was for the same amount as had be…
72. PLR 200118016 — Notification of Secretary of Labor
    IRCPrivate Letter RulingsMay 4, 2001related by meaning
    …30-00/CC:TEGE:EB:QP1 UILC: 4975.07-00 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Central Mountain Area Attn: Laura Beth Heisen FROM: Michael Roach, Chief CC:TEGE:EB:QP1 SUBJECT: Adequacy of Department of Labor Notification Pursuant to I.R.C. §4975(h)…