IRCCourt RulingsFeb 9, 2023★ strong match
…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 by the Tax Re form…
IRCCourt RulingsJun 20, 2001
… the issues for decision are:
1. Whether petitioner’s proper filing status is head of household for 1994 and 1995, as petitioner contends, or married
filing separately, as respondent contends. We hold that it is
married filing separately.
2. Whether petitioner is entitled to the earned income
credit for 1995. We hold t…
IRCCourt RulingsJul 14, 2005related by meaning
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,…
IRCCourt RulingsJan 31, 2001
…d support and alimony.
Former Wife’s counsel did not call this motion up for
hearing until June 23, 1994, at which time the Court removed the freeze on certain assets and temporarily
made certain assets available to the parties for use to
sustain them on an interim basis [by an order filed on
July 1, 1994 (the July 1, …
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 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…
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
01/01/1994
4.25
01/01/1994
04/01/1994
4.50
04/01/1994
05/01/1994
4.75
05/01/1994
07/01/1994
5.25
07/01/1994
08/01/1994
5.50
08/01/1994
09/01/1994
5.75 09/01/1994
11/01/1994
5.50
11/01/1994
12/01/1994
6.00
12/01/1994
01/01/1995
6.25
01/01/1995
04/01/1995
6.00
04/01/1995
05/01/1995
5.75
05/01/1995
07/01/1995
5.50
07/01/1…
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…
IRCCourt RulingsMay 21, 1999
eceived from sales of
insurance in 1994; (3) whether petitioner failed to include $440
in income received from a retirement plan distribution in 1994; (4) whether petitioner is subject to a 10-percent tax on a
premature distribution from a retirement plan in 1994, as
provided under section 72(t); and (5) whether petiti…
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 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 RulingsFeb 24, 2014
the plan. No other contributions
were made during the period under consideration.
On October 6, 1994, K.H. Co., Inc., began operating as K.H. Co. The members of K.H. Co. were Carol Tomb (also known as Carol Hoffman) and the
K.H. Co. Inc. employee stock ownership trust. Immediately before the operating
change Ms. Tomb …
IRCCourt RulingsJul 6, 1998
request form dated October
27, 1994, petitioner elected to receive payment of her entire
account balance in the form of Gillette common stock plus the cash value of any fractional shares of such stock. As of
September 30, 1994, the account had 15.1473 shares of ESOP stock
which were convertible into 302.946 shares of G…
IRCCourt RulingsJun 28, 2010related by meaning
…rt and remanded on another issue .70 F .3d 34, (5th
Cir . 1995) ; Stadnyk v . Commissioner , T .C . Memo . 2008-289, affd .
without published opinion (6th Cir ., Feb . 26,,-2010 )
The settlement agreement . does not expressly allocate or
characterize the settlement payment other than to-state that it
was made "as nonec…
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 …
IRCCourt RulingsMar 24, 2000
…gage
Interest Statement reporting the payment of $8,189.68 in deductible mortgage interest. For the 1994 taxable year,
Transworld Mortgage Corp. issued petitioner and Adrianna a Form
1098 Mortgage Interest Statement reporting the payment of
$7,386.58 in deductible mortgage interest.
After the trial, the record remained…
IRCCourt RulingsDec 19, 1995
…fer Refund does not constitute a qualified total
distribution. See Wittstadt v. Commissioner
, T.C. Memo. 1995492; Humberson v. Commissioner
, T.C. Memo. 1995-470; Pumphrey v.
Commissioner
, T.C. Memo. 1995-469 ; Adler v. Commissioner
, T.C.
Memo. 1995-148; Dorsey v. Commissioner
, T.C. Memo. 1995-97; Brown
v. Commissi…
IRCCourt RulingsFeb 6, 1992related by meaning
Parker, Judge:
By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows:
_Additions to tax_
Sec. Sec. Sec.
TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1/31/86 $64,117 $3,206.85 50 percent $16,029.25
of the interest …
T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner IRCCourt RulingsMar 16, 1999related by meaning
T.C. Memo. 1999-80
UNITED STATES TAX COURT
EDWARD CLASBY AND C.T. GARRAHAN INSURANCE AGENCY, INC.,
Petitioners v
. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1616-97. Filed March 16, 1999.
Paul F. Markham
, for petitioners.
Mark L. Hulse
and Gary W. Bornholdt
, for respondent.
MEMORANDUM FINDINGS OF FACT A…
IRCCourt RulingsJan 13, 2003
…. Meyer) is entitled
to alimony deductions in amounts greater than those conceded by
respondent for 1994, 1995, and 1996; (2) whether Mr. Meyer is
entitled to dependency exemptions for 1994, 1995, and 1996 for
his only child; (3) whether Mr. Meyer is entitled to a child care
credit for 1994, 1995, and 1996; (4) whether…