IRCCourt RulingsFeb 9, 2023★ strong match
year
On or before Apr. 21, 1993 1968 regulations, redesignated in 1993
After Apr. 21, 1993, and on o r
before Oct. 6, 1994
1993 temporary regulations The preamble to the 1994 final regulations contained a discussion
of the legislative history of the commensurate- with-income sentence
that had been added to section 482…
IRCCourt RulingsJul 14, 2005★ strong match
er for calendar year
1993 except that the reference to "20% reduction" was changed to
"50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA
1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this
connection, prior to its amendment by OBRA …
IRCCourt RulingsDec 11, 2003★ strong match
… T.C. 766, 780 (1984), affd. per curiam
793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner
, T.C. Memo.
1985-149; Counts v. Commissioner
, T.C. Memo. 1984-561, affd. 774
F.2d 426 (11th Cir. 1985).
3
See, e.g., Cavanaugh v. Commissioner
, T.C. Memo. 1991407, affd. without published opinion 986 F.2d 1426 (10th Cir.
199…
IRCCourt RulingsMar 6, 2001★ strong match
services
not classified."
The second plan year for the TJM Pension Plan ended October
31, 1993. At trial, petitioner submitted the TJM Pension Plan's Annual Return of Fiduciary of Employee Benefit Trust (Schedule P,
Form 5500), the Return/Report of Employee Benefit Plan (Form
5500-C/R), the Actuarial Information (Sche…
IRCCourt RulingsOct 3, 1995★ strong match
…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 RulingsMar 24, 2000
…ement accounts; and (3)
whether petitioner is liable for additions to tax under section 6651(a) for 1993 and 1994 or under section 6654(a) for 1993.
FINDINGS OF FACT
3
Petitioner resided at 318 Georgia Circle, Placentia,
California, during the tax years at issue and at the time her
petition was filed. Petitioner was bo…
IRCCourt RulingsSep 28, 1998
r in the alternative, that the November 1993
distribution represented a cost-of-living adjustment.
Held
: P modified the series of substantially equal periodic payments by receiving the $6,776 from his IRA in
November 1993 prior to the close of the 5-ye ar period
beginning on the date of the first distribution in
Decem…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
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
5.75
02/01/1993
03/01/1993
5.50
03/01/1993
04/01/1993
5.25
04/01/1993
08/01/1993
5.00
08/01/1993
10/01/1993
4.75
10/01/1993
11/01/1993
4.25
11/01/1993
01/01/1994
4.25
01/01/1994
04/01/1994…
IRCCourt RulingsJun 3, 1998related by meaning
…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 (…
ERISACourt RulingsAug 14, 2026
t this statement “necessarily implies that pre-1993 ret irees had lifetime, uncapped
benefits.” Kaiser, 2024 WL 1283535, at *4. But, read closely, this was not an affirmative statement or argument made by Alcoa;
it was simply a summary of the opposing side’s position. Such
statements cannot trigger judicial estoppel.
Seco…
IRCCourt RulingsJul 31, 2000
…ion 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 Group
Lakewood, do…
IRCPrivate Letter RulingsJun 11, 2004related by meaning
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICA L ADVICE MEMORANDUM
January 07, 2004
Number: 200424004
Release Date: 6/11/04
Third Party Contact:
Index (UIL) No.: 404.11-00, 446.04-03, 446.04-04
CASE-MIS No.: TAM- 127815-03, CC:ITA:B07
Industry Director
------------------------------------------------
Taxpayer's Name…
IRCCourt RulingsSep 18, 1996related by meaning
T.C. Memo. 1996-421
UNITED STATES TAX COURT
JOE M. AND PATRICIA M. BROWN, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9129-93. Filed September 18, 1996.
Robert O. Kazary
, for petitioners.
Alan R. Peregoy
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DAWSON, Judge
: This case was…
IRCCourt RulingsAug 6, 1997
…rs and did not obtain any evidence linking
petitioners to an income generating activity relating to 1993.
Nevertheless, respondent proceeded to use BLS data to reconstruct
petitioners' 1993 income. Therefore, respondent's determinations
relating to petitioners' 1993 tax years are arbitrary, and
respondent bears the bur…
IRCCourt RulingsJan 13, 2003
…Meyer gave birth to the couple’s only
child Richard J. Meyer IV (Richard).
Between February and May 1993, Mr. Meyer, Ms. Meyer, and
Richard moved to Seattle, Washington. In May 1993, Mr. Meyer and
Ms. Meyer separated. Mr. Meyer and Ms. Meyer did not enter into
a formal separation agreement.
After separating, Ms. Meyer …
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 …
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 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 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 RulingsJun 11, 1996related by meaning
…in effect for the taxable year in
issue, and all Rule references are to the Tax Court Rules of
T.C. Memo. 1996-265
UNITED STATES TAX COURT
HAROLD E. EMMONS AND ANNA MAE EMMONS, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20303-94. Filed June 11, 1996.
Janet I. McCurdy
, for petitioners.
Alan…