IRCCourt RulingsJun 20, 2001
1995. We ruled that it
was then too late to raise that issue. Even if we had allowed
petitioner to raise the issue, he did not show he was entitled to deduct car and truck expenses for 1995. At trial, he testified
that he had a mileage log that showed that he used the truck 100
percent for business in 1995. However, he…
IRCCourt RulingsJul 14, 2005related by meaning
…t to answer, respondent asserted increased
deficiencies in tax for petitioner's taxable years 1994, 1995,
and 1996 on the ground that petitioner was not entitled to
petitioner's tentative refunds. The Court stated in Transp.
Labor Contract/Leasing, Inc. & Subs. v. Commissioner, 123 T.C. at
155 n.2:
Our resolution of th…
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 RulingsAug 25, 1997★ strong match
…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 RulingsOct 11, 1995★ strong match
…
liable for the deficiency that respondent determined.
- 7 -
8
See Humberson v. Commissioner
, T.C. Memo. 1995-470;
Pumphrey v. Commissioner
, T.C. Memo. 1995-469 ; Dorsey v.
Commissioner
, T.C. Memo. 1995-97; Brown v. Commissioner
, T.C.
Memo. 1995-93; Hoppe v. Commissioner
, T.C. Memo. 1994-635;
Hamilton v. Commissio…
IRCCourt RulingsSep 18, 1996★ strong match
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 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 2, 2002
…
by the first deed of trust in favor of Great Western. The deed
was executed by David on August 11, 1995, and by Stephanie on August 21, 1995. The fair market value of the Atascadero
property was $207,500 at the time the deed was executed. The
outstanding balances on the loans from Great Western and
petitioner’s profit…
IRCCourt RulingsJan 27, 1998related by meaning
e not binding on any government agency other than the United
States Department of Labor."
On August 18, 1994, respondent issued a notice of deficiency to petitioner, in the amounts set forth above, determining excise
tax deficiencies pursuant to section 4975(a) and (b), as well as
additions to tax. Respondent determine…
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…
IRCCourt RulingsAug 30, 1999
…s unable to borrow against the
marital residence. The only funds available to petitioner in
January 1995 consisted of approximately $33,000 on deposit in two
IRA's that he maintained at BayBank. The foregoing financial
situation with respect to Mr. Czepiel did not change over the
period January 1995 through July 1995.
…
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 RulingsJun 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
IRCCourt RulingsJul 9, 1997related by meaning
ct to the additions under section
6651(a), their failure to file tax returns was not due to
reasonable cause; and, with respect to the additions under section 6654, they do not qualify for any exceptions to the
additions in section 6654(e). The only remaining matters with
respect to additions to tax are computational, …
91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments PBGCProposed Rules (FR)Proposed Jul 6, 2026
…0
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
07/01/1995
09/01/1995
4.75
09/01/1995
10/01/1995
5.00
10/01/1995
12/01/1995
4.75
12/01/1995
02/01/1996
4.50
02/01/1996
04/01/1996…
IRCCourt RulingsJan 31, 2001
…e, therefore, find that
Vanguard intended to name petitioner as recipient of the
Form 1099R.
During 1995, and in accordance with the supplemental final
judgment, petitioner paid Ms. Hodson $3,000 in cash.
By check dated December 21, 1995 (the check), Vanguard
Fiduciary Trust Co. (Vanguard) paid $23,192.18 to the order …
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 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 RulingsApr 12, 2000
itioner in taxable years 1995
and 1996 are includable in gross income. We hold they are. (3)
Whether individual retirement account (IRA) distributions received by petitioner in taxable years 1995 and 1996, as well as
pension and annuity distributions received by petitioner in
taxable year 1996, are includable in gross …
IRCCourt RulingsJan 13, 2003
…r) 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 Mr. M…