IRCCourt RulingsFeb 9, 2023★ strong match
…. See § 1.482-2(d).
Sec. 1.482-1(b)(1), Proposed Income Tax Regs., 57 Fed. Reg. 3578-3579
(Jan. 30, 1992).
The 1992 proposed regulations also contained proposed
replacements to the tran sfer-pricing rules applicable to intangible
property in section 1.482-2(d) of the 1968 regulations. 33 Fed. Reg. 5852
(Apr. 16, 1968);…
IRCCourt RulingsMar 6, 2001★ strong match
…Service. The second ground was that respondent had conducted a
second investigation of petitioner’s 1992 return, without
notifying her of the need thereof, in violation of section
7605(b).
On June 16, 1997, the Chief, Examination Division, Laguna
Niguel, California, mailed petitioner a letter stating, with
regard to th…
IRCCourt RulingsDec 11, 1997★ strong match
ng
bank at the end of 1992.
Based on our examination of the entire record before us, we
find that petitioners have failed to show that they acted with reasonable cause and in good faith, or that they otherwise
exercised due care or made a reasonable attempt to comply with
the Code, when they claimed the 1992 and 1993 d…
IRCCourt RulingsJul 29, 1997★ strong match
…e, e.g., Day v. Commissioner
, 975 F.2d 534, 538
(8th Cir. 1992), affg. in part, revg. in part T.C. Memo. 1991140; Liddy v. Commissioner
, 808 F.2d 312, 315 (4th Cir. 1986),
affg. T.C. Memo. 1985-107.
Petitioner has failed to prove facts to contradict
respondent’s determination of an addition to tax in the amount of
$5…
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 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 RulingsJun 3, 1998★ strong match
…stituted a
modification of the terms of the notes. We have previously
noted that a technical advice memorandum is merely a ruling
given to a specific taxpayer based upon the taxpayer's
specific facts and is not a ruling of general application.
See Golden Belt Tel. Association, Inc. v. Commissioner
, 108
T.C. 498, 506 (…
IRCCourt RulingsNov 25, 1996
…e interest because he used the interest to pay the fee for an
income tax course that he attended in 1992 sponsored by H & R
Block.
Section 61(a)(4) provides that gross income includes
"interest". Petitioner presented no authority to support his
position that he could offset his interest income by the cost of
a tax cour…
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 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…
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
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
6.50
07/01/1992
08/01/1992
6.25
08/01/1992
09/01/1992
6.00
09/01/1992
12/01/1992
5.75
12/01/1992
01/01/1993
6.00
01/01/1993
02/01/1993…
IRCCourt RulingsSep 22, 1998
rm is used in section
7873.
The parties further agree that in 1992 all employees of the
hatchery received, in addition to wages, the choice to have an extra $160 per month paid for their benefit either into a health
plan or a retirement account. Employees could not receive the
monthly additional $160 amount except by c…
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 RulingsMar 3, 1997
e eligible to participate in Varian's pension plan. On
December 31, 1992, Mr. Nicolai had a balance of $377.60 to his
credit in Varian's pension plan. Petitioner Susanne J. Nicolai was employed by Morton F.
Plant Hospital in 1992. Mrs. Nicolai began working at the
hospital in 1990 and terminated her employment during t…
IRCCourt RulingsSep 18, 1996related by meaning
s another matter, and
we can appreciate why respondent focuses on it. However, we are
- 23 -
reminded that petitioner's position as a project engineer required that he be substantially mobile and physically fit in
order to perform his duties. Further, the record clearly
demonstrates that as of October 1989, petitioner …
IRCCourt RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…
IRCCourt RulingsNov 10, 1998
50
Jan. 5, 1990 50
Apr. 18, 1990 1,100
May 4, 1991 $1,400
May 22, 1991 2,000
In 1992, petitioner made the following withdrawals from the IRA
account: Jan. 29, 1992 $1,000
Apr. 6, 1992 2,000
July 21, 1992 2,000
Dec. 7, 1992 1,100
Total 6,100
On December 31, 1992, there was a balance in the IRA account of
$1,374.53.
Pet…
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 RulingsJul 31, 2000
…t No. 1201-97
Addition to Tax
Accuracy-Related Penalty
Year
Deficiency
Sec. 6651(a)(1)
Sec. 6662(a)
1992 $1,620 — $324
1993 6,262 — 1,252 John J. and Ophelia J. Mall, docket No. 1208-97
Addition to Tax
Accuracy-Related Penalty
Year
Deficiency
Sec. 6651(a)(1)
Sec. 6662(a)
1992 $6,186 — $1,237
1993 7,404 — 1,481
Lakewood…