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1. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   d. Reg. 17775), dated May 13, 1993 (58 Fed. Reg. 28446), dated May 18, 1993 (58 Fed. Reg. 28921).” In our view, while the first correction related 214 to both the 1993 temporary regulation and the 1993 notice of proposed rulemaking, the second and third corrections related only to the 1993 temporary regulations. They d…
2. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005★ strong match
   0 31 useaee CAL, Js.r. Juoca T.C. Memo. 2005-173 UNITED STATES TAX COURT TRANSPORT LABOR CONTRACT/LEASING, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 1188-01. Filed July 14, 2005. Michael I. Saltzman, Kathleen Pakenham, and Todd C. Simmens, for petitioner. Jack Forsberg,…
3. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
   IRCCourt RulingsMar 6, 2001★ strong match
   v. Commissioner , T.C. Memo. 1998-140; Reiher v. Commissioner , T.C. Memo. 1998-75; Easter v. Commissioner , T.C. Memo. 1998-8; Brewer v. Commissioner , T.C. Memo. 1997-542, affd. without published opinion 172 F.3d 875 (9th Cir. 1999); Gillette v. Commissioner , T.C. Memo. 1997-301; Hayes v. Commissioner , T.C. Memo. 1…
4. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
   IRCCourt RulingsOct 3, 1995★ strong match
   … more equitable result. See Hildebrand v. Commissioner , 683 F.2d 57, 58 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Zadan v. Commissioner , T.C. Memo. 1993-85. After all, the power to legislate is exclusively the power of Congress and not of this Court or any other. See Iselin v. United States , 270 U.S. 245, 250 (1926…
5. T.C. Memo. 2000-100 — Ronna Joan Robertson v. Commissioner
   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…
6. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
   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 (…
7. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
   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…
8. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
   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))…
9. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
   IRCCourt RulingsJun 18, 1999related by meaning
   …statutory interest imposed under section 6601. See Bax v. Commissioner , 13 F.3d 54, 56-57 (2d Cir. 1993), affg. an Order of this Court; LTV Corp. v. Commissioner , 64 T.C. 589, 597 (1975);
10. 111 T.C. No. 12 — Robert C. & Nancy L. Arnold v. Commissioner
    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…
11. 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…
12. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    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…
13. Court of Appeals for the Seventh Circuit — Lynnette Kaiser v. Alcoa USA Corp.
    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…
14. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    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…
15. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
    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 …
16. T.C. Memo. 2000-384 — Robert W. & Vivian Toan v. Commissioner
    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 …
17. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    … • warnings that he was in danger of being penalized. For example, in Mathews v. Commissioner, T.C. Memo. 2005-84, we told petitioner: "Even though the filing of the petition resulted in respondent's concession of the sec. 72(t) additional tax,
18. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    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…
19. T.C. Memo. 2003-12 — Richard J. Meyer, III v. Commissioner
    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 …
20. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
    IRCCourt RulingsNov 25, 2009related by meaning
    t affect the tax treatment - 5 under the Internal, Revenue Code . See sec . 7701(j)(5) ("No provision of law not contained in this title [the internal Revenue Code] shall apply for purposes of determining the treatment under this title of the Thrift Savings Fund or any contribution to, or distribution from, such Fund .…