IRCCourt RulingsFeb 9, 2023★ strong match
… and June
30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon
Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M.
(CCH) 1707 (a case involving tax years 1979, 1980, and
1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d
825 (5th Cir. 1996)
In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
IRCCourt RulingsAug 25, 1997★ strong match
…ircuit decided Adler v. Commissioner
, 86 F.3d 378, which vacated
and remanded our decision in T.C. Memo. 1995-148. In Adler v.
Commissioner
, the Court of Appeals agreed that the phrase "on
account of" requires "a causal connection between the employee's
IRCCourt RulingsJul 14, 2005related by meaning
…r, 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 the issue re…
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…
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 RulingsSep 3, 1998★ strong match
…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.…
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…
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 …
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…
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 RulingsJun 18, 1999related by meaning
1
Unless otherwise indicated, all section references are to
(continued...)
T.C. Memo. 1999-199
UNITED STATES TAX COURT
DON LAVERNE CLARKE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 151-97. Filed June 18, 1999.
Don Laverne Clarke, pro se.
Anthony Hoefer
, for respondent.
MEMORANDUM FINDINGS …
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…
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…
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 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…
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…
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…
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…
T.D. 9256 — Final regulations under section 417 of the Code concern content requirements applicable to explanations of qualified joint and survivor annuities and qualified… IRCTreasury DecisionsApr 17, 2006related by meaning
SPECIAL ANNOUNCEMENT
Announcement 2006-22 Announcement 2006-22
This document contains the annual report to the public concerning Advance Pricing Agreements (APAs) and the experience of the APA program during calendar year 2005. This document does not provide guidance regarding the application of the arm’s length standa…
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 .…