IRCCourt RulingsFeb 9, 2023related by meaning
… and June
30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon
Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M.
(CCH) 1707 (a case involving tax years 1979, 1980, and
1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d
825 (5th Cir. 1996)
In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
IRCCourt RulingsJul 14, 2005related by meaning
48 F.2d 306, 310 (9th Cir.
1945), affg. a Memorandum Opinion of this Court dated Jan. 5,
1943; Standard Knitting Mills, Inc. v. Commissioner, 141 F.2d 195, 198-199 (6th Cir. 1944), affg. 47 B.T.A. 295 (1942).
Generally, new issues may not be raised in a Rule 155
computation. Harris v. Commissioner, 99 T.C. 121, 123 (19…
IRCCourt RulingsMay 28, 2003
…xaminations of petitioner and of Duncan & Associates with respect to their respective taxable years 1990
and 1991.
On October 8, 1992, petitioner filed Federal income tax
(tax) returns for his taxable years 1990 (1990 return) and 1991
(1991 return) after the respective due dates for such returns had
passed. Petitioner …
IRCCourt RulingsDec 20, 2001
…y McLaughlin (Mr. McLaughlin) owned 24,000
shares of that stock (the McLaughlin shares).
On May 25, 1990, Mr. Johnston, Jacque Johnston, and Mr.
McLaughlin entered into a stock purchase agreement (May 25, 1990
stock purchase agreement) with Mr. Stanford, Mr. Whitehead,
Patrick Watson (Mr. Watson), Gerald Buchner (Mr. B…
T.C. Memo. 1998-145 — Estate of Hilda Ashman, Deceased; Phillip Ashman, Personal Representative v. Commissioner IRCCourt RulingsApr 22, 1998
bution. We find that
respondent reasonably relied on decedent's 1990 return, did not
- 13 -
challenge decedent's representations regarding the pension distribution, and allowed the period of limitations for 1990 to
expire.
(3) Decedent’s Change of Position or Representation for 1993
With respect to the third element re…
IRCCourt RulingsDec 23, 1996★ strong match
… (1939).
Respondent cites Tucker v. Commissioner
, 69 T.C. 675 (1978),
Kuntz v. Commissioner
, T.C. Memo. 1992-650, and Kasey v.
Commissioner
, T.C. Memo. 1976-266, in support of her position.
As discussed below, respondent's reliance on these cases is
misplaced.
In Tucker v. Commissioner
, supra
, the taxpayer was a t…
IRCCourt RulingsJun 3, 1998★ strong match
ute are as follows:
- 5 -
Revised
Year
Deficiency
Sec. 6662 Penalty
1990 $9,603 $1,921
1991 22,648 4,530
Respondent computed the amount of the revised deficiency for 1990 by treating the principal amount of
each of the loans that petitioner received in 1990 as a
taxable distribution of plan assets in that year (viz
$24…
IRCCourt RulingsApr 30, 1997
…ge payments, ranging from 100 percent to just under
50 percent, as follows:
Payment
Due Date
Feb.1, 1990
Apr.1, 1990
May 1, 1990
June 1, 1990
July 1, 1990
Aug.1, 1990
Total
Payment
$1,894.48
1,894.48
1,894.48
1,894.48
2,256.53
2,256.53
Payment By
Petitioner
$1,894.48
1,894.48
914.48
949.48
1,292.53
1,128.53
Petitioner'…
IRCRegulationsSep 9, 2016
…refore, in determining the group of highly compensated employees for the April 1, 1989 to March 31, 1990 plan year, the determination year is the plan year ending March 31, 1990 and the look-back year is the plan year ending March 31, 1989. Example 2.Assume the same facts given above. With respect to the plan year begi…
IRCCourt RulingsOct 17, 1995
…wable itemized deductions. Respondent concedes
that petitioners repaid unemployment compensation in 1990 in the amount of $1,715 and are entitled to rental depreciation of
$2,889 for 1990.
$5,952 and $6,471.50, and an accuracy-related penalty under
section 6662(b)(1) for 1990 in the amount of $1,294.30.
After concessio…
IRCCourt RulingsOct 3, 1995
…Pension System but had retired under the
Retirement System.
Petitioner's Retirement On February 28, 1990, after he had elected to transfer from
the Retirement System to the Pension System, petitioner executed
a Letter of Intent in which he advised the Garrett County Board
of Education of his intent to retire by July 1,…
IRCCourt RulingsSep 18, 1996
iency Determination For 1990
In the notice of deficiency for 1990, respondent determined
that petitioners are liable for: (1) The additional tax under section 72(t) for a premature distribution from petitioner's IRA
with First National, and (2) the excise tax under section 4980A
for an excess distribution from such IRA…
IRCCourt RulingsJun 12, 1996★ strong match
…etitioners are liable for an addition to tax
under section 6651(a) for failure to timely file their 1990 income tax return. We hold that they are not.
(3) Whether petitioners are liable for an accuracy-related
penalty under section 6662(a) due to a substantial understatement
of income tax. We hold that they are.
FINDIN…
IRCCourt RulingsDec 19, 2000related by meaning
ec. 402(a), 96 Stat. 324,
648, but had to be determined in the Toans’ individual case.
Alternatively, petitioners argue, any assessment under the 1980 notice is time barred under section 6501. Petitioners assert
that the addition to tax under section 6659 was an affected item
- 7 -
for 1982 and that the related notice …
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…5
08/01/1989
09/01/1989
7.50
09/01/1989
10/01/1989
7.25
10/01/1989
12/01/1989
7.50
12/01/1989
03/01/1990
7.25
03/01/1990
06/01/1990
7.50
06/01/1990
07/01/1990
7.75
07/01/1990
09/01/1990
7.50
09/01/1990
10/01/1990
7.25
10/01/1990
11/01/1990
7.50
11/01/1990
12/01/1990
7.75
12/01/1990
01/01/1991
7.50
01/01/1991
03/01/1991…
IRCCourt RulingsNov 7, 1996related by meaning
is written, and, even if
petitioner's argument might accord with good policy, we are not
at liberty to rewrite such section because we might deem its effects susceptible of improvement. Commissioner v. Lundy
, 516
U.S.
116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing
Badaracco v. Commissioner
, 464 U.S. 386, 398 (1984))…
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 RulingsAug 25, 1997related by meaning
…reply brief includes 4-½ pages of objections to respondent's
proposed findings of fact. Id
.
I. The Memorandum Opinion
In T.C. Memo. 1995-492, filed October 11, 1995, the Court
decided the present case. In our memorandum opinion, we rejected
petitioners' argument that petitioner's Transfer Refund had not
been received …
IRCCourt RulingsAug 8, 1996related by meaning
to the Internal Revenue
Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L.
104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after
July 30, 1996. Because this case does not involve a request for
abatement after July 30, 1996, we lack jur…
IRCCourt RulingsMar 6, 2001★ strong match
…75), affd. without published opinion 552 F.2d 368
(5th Cir, 1977); Kiourtsis v. Commissioner
, T.C. Memo. 1996-534; Fitzpatrick v. Commissioner
, T.C. Memo. 1995-548. Even after she
received the no change letter, petitioner was aware that the 1992
tax year remained open. Petitioner signed three consents to
extend the t…