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61. 108 T.C. No. 12 — American Stores Company and Subsidiaries v. Commissioner
    IRCCourt RulingsMar 31, 1997related by meaning
    pined that, because the taxpayer was late in filing its 1989 tax return, it could not have interfered with the ability of other employers to calculate and claim their deductions. Airborne Freight Corp. v. United States , 76 AFTR 2d 95-7497, at 95-7499, 96-1 USTC par. 50,004, at 83,015 (W.D. Wash. 1995). The District Co…
62. 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…
63. 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…
64. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    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…
65. 95 T.C. 132; 95 T.C. No. 11 — Thoburn v. Commissioner
    IRCCourt RulingsAug 13, 1990related by meaning
    et interest rate for the use of money shall be the higher of the rate on the date of the prohibited transaction or the rate on the date of correction. If a prohibited transaction is not corrected within the taxable period, disqualified persons participating in the prohibited transaction become liable for a second-tier …
66. 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…
67. T.D. 9275 — Final regulations under section 410 of the Code implement a statutory directive of the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) to am…
    IRCTreasury DecisionsAug 28, 2006related by meaning
    n the information elicited on those line items, as well as the rest of the form, in their books and records. Announcement 2006-56 Announcement 2006-56 This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a dedu…
68. 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…