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81. T.C. Memo. 2017-69 — Larry E. Austin & Belinda Austin v. Commissioner
    IRCCourt RulingsApr 24, 2017
    Commissioner, T.C. Memo. 2015-123, 110 T.C.M. (CCH) 17, afD, 845 F.3d 555 (4th Cir. 2017). We there held, and the Court of Appeals agreed, that stock °The problem with Varde was apparently resolved six months later. In November 2003 the portfolios held by Rescomm were transferred to Holdings. - 28 - [*28] issued by an…
82. T.D. 9164 — Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409…
    IRCTreasury DecisionsJan 18, 2005related by meaning
    s an avoidance or evasion of section 409(p). A public hearing on the proposed regulations is scheduled for April 20, 2005. REG–129709–03 REG–129709–03 Temporary and proposed regulations under section 409(p) of the Code provide guidance on the definition and effects of a prohibited allocation under section 409(p), ident…
83. T.C. Memo. 1995-539 — Guy Schoenecker, Inc.; Business Incentives, Inc.; and Carousel By Guy, Inc. v. Commissioner
    IRCCourt RulingsNov 14, 1995
    988, $110,000 for its fiscal year 1989, $122,500 for its fiscal year 1990, and $215,000 for its fiscal year 1991. For its fiscal year 1988 Animal Fair paid Mr. Richard Duff $103,750 and Mr. Dean Fitch $156,922 for service for three-quarters of the year, and Mr. William Jeurgens - 13 - $122,047. For its fiscal year 1989…
84. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    cts and circumstances, it is inequitable to hold the individual liable for any unpaid tax or any deficiency (or any portion of either) attributable to any item for which relief is not available under the preceding sentence, the Secretary may relieve such individual of such liability. . Petitioner's request for relief r…