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61. U.S. Tax Court — Susan Elizabeth Machlay v. Commissioner
    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 …
62. T.C. Memo. 2011-110 — Michael Rosenfeld v. Commissioner
    IRCCourt RulingsMay 23, 2011
    d to an SEP plan on the basis of these earnings.6 In 2003 he contributed $12,242 to his SEP plan. In the notice of deficiency respondent determined in pertinent part that petitioner was:; (1)- A common law employee of the BCG and consequently was not entitled to report gross receipts and expenses associated with his wo…
63. T.C. Summary Opinion 2001-158 — Majid Naemi v. Commissioner
    IRCCourt RulingsSep 26, 2001related by meaning
    1 All subsequent section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are 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 REVEN…
64. T.C. Memo. 2009-100 — Peter I. & Daria A. Basalyk v. Commissioner
    IRCCourt RulingsMay 14, 2009
    …of the Memphis and Forest Lakes properties were $92,480 and $53,880, respectively . Tax Years 2002, 2003, and 200 4 During 2002, 2003, and 2004 petitioner Daria A . Basalyk (Mrs . Basalyk) was an employee of the Brecksville-Broadview Heights Board of Education . Petitioner Peter I . Basalyk (Mr . Basalyk) was an employ…
65. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004related by meaning
    …ent’s litigating position that the distribution occurred in 2000. See Garcia v. Commissioner , T.C. Memo. 1998-203 (reaching this conclusion regarding another question and answer contained in the same proposed regulation), affd. without published opinion 190 F.3d 538 (5th Cir. 1999). Additionally, the substantially lev…
66. T.C. Memo. 2015-244 — Jeremiah J. O'Connor & Mary K. O'Connor v. Commissioner
    IRCCourt RulingsDec 16, 2015
    …ed by the Trust in order to fully liquidate the Trust and make final distributions."7 On October 7, 2003, Mr. O'Connor, on behalf of Hardware, executed the termination of participation in the Advantage Plan resolution (Hardware's termination resolution) previously forwarded to him, in blank, by BISYS, Hardware's withdr…
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. T.C. Memo. 2012-329 — Thomas S. Gluckman & Roby R. Gluckman v. Commissioner
    IRCCourt RulingsNov 28, 2012
    …03. Starting in January 2003 and continuing throughout the year, BISYS sent a series of letters and memoranda to insurance agents, brokers, and p rticipating employers to adviãe them of the approaching termination of the Ad antage Plan and the options that participating employers and employees had as result of the term…
69. T.C. Memo. 2007-360 — Rodolfo & Bernadette Domingo v. Commissioner
    IRCCourt RulingsDec 5, 2007
    lises Survivor Whole Life Polic y On July 28 , 2003, STEP assigned the ownership of the DeAngelises survivor whole life policy to the DeAngelises . No severance event had occurred under the STEP plan to permit this assignment . In connection with the assignment , Dr . DeAngelis also executed a claim settlement and rele…
70. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    ). VIII. Conclusion Petitioners received railroad retirement and Social Security benefits from the RRB during each of the years in issue . Petitioners have failed to prove that respondent incorrectly determined the adjustments to petitioners’ income on the basis of amounts that were not reported in the information retu…
71. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
    IRCCourt RulingsAug 28, 2008related by meaning
    T .C . Memo . 2008-20 4 UNITED STATES TAX-COUR T WALTER KOWSH, Petitioner v . COMMISSIONER OF . INTERNAL . REVENUE, Responden t Docket No . 15154-06 . Filed August 28, 2008 . Walter Kowsh, pro se . Michelle L . Maniscalco , for respondent . MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N KROUPA, Judge : Respondent determined…
72. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003
    … T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, affd. 774 F.2d 426 (11th Cir. 1985). 3 See, e.g., Cavanaugh v. Commissioner , T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir. 199…
73. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
74. T.C. Summary Opinion 2013-51 — Martin Toombs v. Commissioner
    IRCCourt RulingsJun 25, 2013related by meaning
    T.C. Summary Opinion 2013-51 UNITED STATES TAX COURT MARTIN TOOMBS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27665-10S. Filed June 25, 2013. James O. Creech III, for petitioner. Thomas D. Yang, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was heard pursuant to the p…
75. T.C. Summary Opinion 2008-1 — Shawn Timothy Hynes v. Commissioner
    IRCCourt RulingsJan 2, 2008
    ork City to Palo Alto . Petitioner timely filed his 2003 Federal income tax return . Petitioner reported wages, salaries, and tips on his return . His wages of $51,304 were earned from his employment at STB from September through December of 2003 . Respondent received the following third party information for petitione…
76. Rev. Proc. 2004-6 — Employee plans determination letters. Revised procedures are provided for issuing determination letters on the qualified status of employee plans under section…
    IRCRevenue ProceduresSuperseded Jan 5, 2004
    … as modified by Rev. Proc. 2000-27, Notice 2001-42, Rev. Proc. 2001-55, 2001-2 C.B. 552, Rev. Proc. 2003-6, Rev. Proc. 2002-29, 2002-1 C.B. 1176 (as modified by Rev. Proc. 2003-10, 2003-2 I.R.B. 259), Rev. Proc. 2002-73, 2002-2 C.B. 932, and Rev. Proc. 2003-72, 2003-38 I.R.B. 578. (3) Technical advice requests: See Rev…
77. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    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…