IRCCourt RulingsJul 14, 2005related by meaning
ll other agreements between the parties. The
parties stipulate that neither of them has made any
representations with respect to the subiect matter of this Agreement or any representations * * * except such
representations as are specifically set forth herein
and each of the parties hereto acknowledges that he or
they …
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 25, 1997
…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 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 RulingsJul 11, 2024related by meaning
…ation software is only as good as the information one puts into it.”).
21
[* 21] Commissioner, T.C. Memo. 1996-140 , 71 T.C.M. (CCH) 2526 , 2526
(“ [The tax p ayers] argue that benefits received from the [RRB] are not
taxable. This , however , is simply not the case.”).
VIII. Conclusion
Petitioners received railroad re…
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 19, 2000related by meaning
limitation would have
expired.
- 11 -
Nor does the fact that respondent had already issued
petitioners a notice of deficiency for 1980 (i.e., the 1984 notice) serve to prohibit respondent from issuing the affected
items notice of deficiency to petitioners for the same year. See
sec. 6230(a)(2)(C); Hemmings v. Commissio…
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 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 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 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…
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…
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 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 RulingsNov 7, 1996★ strong match
ons under section
4980A(a). See Emmons v. Commissioner
, T.C. Memo. 1996-265;
Powell v. Commissioner
, T.C. Memo. 1996-264; Montgomery v.
Commissioner , T.C. Memo. 1996-263; see also O'Connor v.
Commissioner
, T.C. Memo. 1994-170 (regarding section 4974).
B. Petitioner's Contention
Notwithstanding the foregoing, petiti…
IRCPrivate Letter RulingsAug 27, 1999related by meaning
…Number: 199934002
Release Date: 8/27/1999
INTERNAL REVENUE SERVICE
NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM
Taxpayer's Name:
Taxpayer's Address:
Taxpayer's Ident. No.:
Taxable Years at Issue:
Date of Conference:
Legend
:
Taxpayer =
Plan =
Trust Agreement =
ISSUES
:
(1) Whether, under the rules of section 461 of the …
Rev. Proc. 2013-5 — Technical advice. Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissione… IRCRevenue ProceduresJan 2, 2013related by meaning
ed do not apply to requests for any documents to the extent § 6104 applies.
Statement identifying information to be deleted from public inspection
.04 The text of a TAM subject to § 6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection…
IRCCourt RulingsSep 3, 1998
…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.…