IRCCourt RulingsFeb 9, 2023★ strong match
… 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
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
IRCCourt RulingsDec 11, 1997
…the Hickman corporation profit-sharing plan, sent
respondent's Appeals Officer who was handling the 1991 audit a
letter dated October 18, 1991, which set forth the final resolution of that audit (1991 settlement). The 1991 settlement
provided, inter alia, that petitioner was to correct
the alleged prohibitive [sic] tra…
120 T.C. No. 5 — Wells Fargo & Company, f.k.a. Norwest Corporation and Subsidiaries v. Commissioner IRCCourt RulingsFeb 13, 2003
…ocket Nos. 7620-98, 12136-98, Filed February 13, 2003.
19891-98, 7282-99,
12484-99.
1
For the years 1991-94, Ps made contr ibutions to a
voluntary employee benefit trust (the postretirement
medical trust) for the purpose of providing
postretirement medical benefits to their employees. For
1991, Ps’ actuary computed the…
IRCCourt RulingsJun 3, 1998★ strong match
…________
24,000.00 5,100.82 $29,100.82
Respondent computed the amount of the revised
deficiency for 1991 by treating the principal amount
of each of the loans that petitioner received in 1991
as a distribution of plan assets in 1991 (viz $3,827, as
shown in the following schedule). In addition, respondent
treated the a…
IRCCourt RulingsMay 28, 2003
0 and
1991, respectively.
At a time not disclosed by the record before September 1992,
respondent commenced examinations 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…
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 …
IRCCourt RulingsJul 31, 2000★ strong match
…t No. 2995-97
Addition to Tax
Accuracy-Related Penalty
Year
Deficiency
Sec. 6651(a)(1)
Sec. 6662(a)
1991 $169,437 — $33,887
1991 — — —
1992 71,110 $10,667 14,222
1993 93,111 — 18,622
Estate of Steven Sobo, Deceased, Bonnie Sobo, Executrix, and
Bonnie Sobo, docket No. 2795-97
Addition to Tax
Accuracy-Related Penalty
Yea…
IRCCourt RulingsAug 8, 1996★ strong match
…ylvania, in 1955.
He lived in Pittsburgh and worked for Westinghouse Electric Co.
- 3 -
(WEC) until 1991. In July 1991, petitioner ceased employment at
WEC, moved to Georgia, and began working for Westinghouse
Savannah River Co. (WSR).
Petitioners purchased a home in Evans, Georgia, on September
30, 1991, for $219,900.…
IRCCourt RulingsJun 18, 1999related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
IRCCourt RulingsMar 6, 2001
ounsel in his memo of
April 8, 1994), that the provisions of the Civil Rights Act of
1991, Pub. L. 90-202, 81 Stat. 602, governing expert witness fees applied retroactively, it turned out that respondent was
mistaken. The amendments made by the Civil Rights Act of 1991,
which provided for additional relief of compensat…
ERISACourt RulingsFeb 1, 1993
h 13, 1991, attorney
Richard B. Fellows responded on Respondent's behalf by letter to
Joseph Roberts of DRC, referencing a telephone conversation with r. Roberts on March 13, 1991, and advising that steps were being
taken to compile an accountant's report, and an attempt would be
made to file these accountant's reports…
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 …
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
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
7.25
03/01/1991
06/01/1991
7.00
06/01/1991
07/01/1991
6.75
07/01/1991
10/01/1991
7.00
10/01/1991
01/01/1992
6.75
01/01/1992
02/01/1992
6.50
02/01/1992
03/01/1992
6.25
03/01/1992
07/01/1992…
117 T.C. No. 19 — The Board of Trustees of the Sheet Metal Workers' National Pension Fund, In Its Capacity As Plan Administrator v. Commissioner IRCCourt RulingsDec 4, 2001
l COLA Fund was amended
to provide for a 1-percent cost-of-living benefit. In December
1991, the COLA Fund paid .96 percent as a COLA benefit, and the NPF Fund paid 2.04 percent.
In March 1992, petitioner adopted a new article 8 that
formally added the NPF COLA to the Plan, effective retroactively
to January 1, 1991. I…
88 FR 78134 — Income and Currency Gain or Loss With Respect to a Qualified Business Unit IRCProposed Rules (FR)Proposed Nov 14, 2023
ction 987
A. 1991 Proposed Regulations and Notice 2000-20
On September 25, 1991, the Treasury Department and the IRS published in the
Federal Register proposed regulations under section 987 (56 FR 48457, September 25, 1991) (“1991 proposed regulations”). The 1991 proposed regulations provided that section 987 taxable i…
IRCCourt RulingsMar 25, 1996★ strong match
T.C. Memo. 1996-146
UNITED STATES TAX COURT
LLOYD PATTERSON, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1254-94. Filed March 25, 1996.
Lloyd Patterson, pro se.
Patricia Riegger
, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge
: This case was heard pursuant to
section 7443A(b)(…
IRCCourt RulingsMar 20, 1997related by meaning
performed by anyone
else.
Discussion
Petitioners bear the burden of establishing that
respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a);
Welch v. Helvering
, 290 U.S. 111 (1933). Petitioners' briefs
refer to several facts which were not included…
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))…
IRCPrivate Letter RulingsMar 3, 2000related by meaning
…C:EBEO:4
TL-N-4712-99
UILC: 419.00-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR
FROM: Assistant Chief Counsel (Employee Benefits and Exempt
Organizations) CC: EBEO
SUBJECT:
This Field Service Advice is in res ponse to your memorandum dated October 5,
1999. Field Service Advice is not …