IRCCourt RulingsDec 11, 1997★ strong match
…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 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 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 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 RulingsAug 8, 1996★ strong match
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 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 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…
IRCCourt RulingsSep 3, 1998★ strong match
…his Court under substantially identical circumstances. See
Steel Balls, Inc. v. Commissioner
, T.C. Memo. 1995-266, affd.
without published opinion 89 F.3d 841 (8th Cir. 1996).
6
We
rejected the same argument presented herein and concluded that
respondent's position was clearly supported by the statute and
regulations.…
IRCCourt RulingsOct 3, 1995related by meaning
…e year in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
T.C. Memo. 1995-470
UNITED STATES TAX COURT
HAROLD L. AND GLADYS M. HUMBERSON, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10066-93. Filed October 3, 1995.
Harold L. Humberson, pro se.
Alan R. Pere…
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…
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…
IRCCourt RulingsNov 7, 1996related by meaning
T.C. Memo. 1996-502
UNITED STATES TAX COURT
ELAINE S. BENNETT, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8545-96. Filed November 7, 1996.
Vernon E. Robbins
, for petitioner.
Alan R. Peregoy
, for respondent.
MEMORANDUM OPINION
DAWSON, Judge
: This case was assigned to Special Trial
Judge Ro…
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 RulingsJan 13, 1997
…unts at Fluor Daniel, the "Retirement Plan" and
the "Savings Investment Plan." Sometime in March of 1991,
petitioner asked the plan administrator at Fluor Daniel to
distribute to him the entire balance of each retirement account.
By letters dated May 7 and May 13, 1991, the plan administrator
acknowledged petitioner's …
IRCPrivate Letter RulingsAug 27, 1999related by meaning
…Number: 199934002
Release Date: 8/27/1999
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Taxpayer's Name:
Taxpayer's Address:
Taxpayer's Ident. No.:
Taxable Years at Issue:
Date of Conference:
Legend
:
Taxpayer =
Plan =
Trust Agreement =
ISSUES
:
(1) Whether, under the rules of section 461 of the …
IRCCourt RulingsDec 20, 2001
…ed agent of the Corporation.
Burien Nissan experienced financial difficulties during 1990
and early 1991. On a date during 1991 not disclosed by the
record, Mr. Stanford accepted an offer to manage a large automobile dealership in Hawaii. On September 13, 1991, Mr. Whitehead
and Mr. Stanford entered into a stock purcha…