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1. T.C. Memo. 1997-389 — Glenn L. Wittstadt, Jr. & Lynne M. Wittstadt v. Commissioner
   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 …
2. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   IRCCourt RulingsFeb 9, 2023★ strong match
   …public received notice of the content of the regulation. Under the effective- date provision of the 1996 amendment, the 1996 amendment applied “with respect to regulations which relate to statutory provisions enacted on or after the date of the enactment of this Act [July 30, 1996].” Taxpayer Bill of Rights 2, sec. 110…
3. T.C. Memo. 2005-173 — Transport Labor Contract/Leasing, Inc. & Subsidiaries v. Commissioner
   IRCCourt RulingsJul 14, 2005related by meaning
   …to calculate the correct amounts of the deficiencies for petitioner's taxable years 1994, 1995, and 1996, respectively, to add the amount of the tentative refund for each such taxable year to the amount of the deficiency that respondent had determined in the notice for each such year. Sec. 6211(a) and (b). That was the…
4. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
   IRCCourt RulingsOct 29, 2002
   … in 1989 when he had diplomatic status. Petitioner claimed a $4,237 net operating loss (NOL) on his 1996 return. In a separate statement attached to his 1996 return, petitioner identified the NOL as a "net operating loss carryover", but he did not state from which year or years he was carrying the loss, Respondent sent…
5. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
   IRCCourt RulingsNov 7, 1996★ strong match
   …ects 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)). Accordingly, in order to give effect to our disposition of the disputed issue, as well as respondent's concession, and to permit - 16 - 12 See supra no…
6. T.C. Memo. 2003-223 — Richard Wos v. Commissioner
   IRCCourt RulingsJul 29, 2003
   time he filed the petition in this case, petitioner’s address was in Morton Grove, Illinois. During 1996 and 1997, petitioner was engaged in a washing machine repair business from which he had net profit of $30,200.31 and $30,227.02, respectively. On April 18, 1996, respondent received from petitioner an estimated tax …
7. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
   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 (…
8. T.C. Memo. 2001-317 — Herbert L. & Jennifer L. Whitehead v. Commissioner
   IRCCourt RulingsDec 20, 2001
   hat they contend Ms. Whitehead performed for Burien Nissan during 1996, her compensation for those services would have been $2,040, which is an amount substantially less than the value ($6,600) that petitioners claimed in their 1996 joint return. Assuming arguendo that Ms. Whitehead had worked 120 hours for Burien Niss…
9. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
   IRCCourt RulingsAug 8, 1996related by meaning
   …iew 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 jurisdiction to abate - 8 - interest herein. See Commissioner v. McCoy , 484 U.S. 3, 7 (1987); 508 Clinton Street Corp. v. Com…
10. T.C. Memo. 2003-12 — Richard J. Meyer, III v. Commissioner
    IRCCourt RulingsJan 13, 2003
    …tled 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. Meyer is li…
11. T.C. Memo. 2006-106 — Susan F. Mostafa v. Commissioner
    IRCCourt RulingsMay 15, 2006
    ceived wage income of $1,076. Petitioner had three IRAs during 1996,. one account with T. Rowe Price (the T. Rowe Price IRA) and two accounts with the Lindner Growth Fund administered by Star Bank (the first Star Bank IRA and the second Star Bank IRA, respectively). On February 26, 1996, petitioner received a $7,000 di…
12. T.C. Memo. 1995-470 — Harold L. & Gladys M. Humberson v. Commissioner
    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…
13. 91 FR 40954 — Improvements to Rules on Recoupment of Benefit Overpayments
    PBGCProposed Rules (FR)Proposed Jul 6, 2026
    …0 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 4.25 04/01/1996 05/01/1996 4.75 05/01/1996 08/01/1996 5.00 08/01/1996 11/01/1996 5.25 11/01/1996 12/01/1996 5.00 12/01/1996 01/01/1997 4.75 01/01/1997 02/01/1997 4.50 02/01/1997 03/01/1997…
14. T.C. Memo. 2002-123 — Edward Kenneth Metcalf v. Commissioner
    IRCCourt RulingsMay 22, 2002
    … responded with instructions for the bank to mail him a check for the minimum withdrawal amount. In 1996, petitioner mistakenly signed a form to close out his IRA as of December 31, 1996. On December 31, 1996, Key Bank closed petitioner’s IRA account and sent petitioner the entire balance. Petitioner reported his entir…
15. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000★ strong match
    …fe Ins. Co. v. Commissioner , 106 T.C. 274, 302 (1996); see also M.I.C. Ltd. v. Commissioner , T.C. Memo. 1997-96; Proios v. Commissioner , T.C. Memo. 1994-442. Other times, he or she will not. See, e.g., Estate of Scanlan v. Commissioner , T.C. Memo. 1996-331, affd. without published opinion 116 F.3d 1476 (5th Cir. 19…
16. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    IRCCourt RulingsSep 3, 1998related by meaning
    …his Court under substantially identical circumstances. See Steel Balls, Inc. v. Commissioner , T.C. Memo. 1995-266, affd. without published opinion 89 F.3d 841 (8th Cir. 1996). 6 We rejected the same argument presented herein and concluded that respondent's position was clearly supported by the statute and regulations.…
17. T.C. Memo. 2001-55 — Taylor Miller v. Commissioner
    IRCCourt RulingsMar 6, 2001
    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…
18. 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 …
19. T.C. Memo. 1996-421 — Joe M. & Patricia M. Brown v. Commissioner
    IRCCourt RulingsSep 18, 1996★ strong match
    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…
20. T.C. Summary Opinion 2001-168 — Mary Holland Trull v. Commissioner
    IRCCourt RulingsOct 23, 2001
    l January 17 , when she was laid off. The official termination date on CP&L records is March 20, 1996. During her employment with CP&L, petitioner was covered by an employer pension plan. She was vested in the CP&L pension plan. Petitioner contributed $1,175.46 to the CP&L pension plan in 1996. Even though her employme…