IRCCourt RulingsNov 21, 2007
… distributions from his IRA in the
aggregate amount of $331,500, as follows : Date Amoun t
Jan . 4, 1999 $70,00 0
Jan . 4, 1999 20,00 0
Feb . 1, 1999 15,00 0
Apr . 26, 1999 30,000
-11May 13, 1999 30,00 0
May 31, 1999 15,00 0
July 19, 1999 20,00 0
July 19, 1999 50,00 0
Sept . 20, 1999 10,00 0
Oct . 18, 1999 20,00 0
Oct …
IRCCourt RulingsJul 14, 2005related by meaning
er for calendar year
1993 except that the reference to "20% reduction" was changed to
"50% percent reduction" in order to reflect changes made to sec. 274(n)(1) by the Omnibus Budget Reconciliation Act of 1993 (OBRA
1993), Pub. L. 103-66, sec. 13209(a), 107 Stat. 469. In this
connection, prior to its amendment by OBRA …
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 RulingsJun 9, 2005
…medical treatment received by petitioner and/or
petitioner’s family members during the taxable year 1999.
Exhibits 3-J, 4-J, and 5-J consisted of documents reflecting the
medical expenses which respondent conceded, along with the health
insurance premiums in the aggregate amount of $1,390 paid by
petitioner during taxa…
IRCCourt RulingsFeb 9, 2023related by meaning
… 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 RulingsNov 1, 2005★ strong match
…d all Rule references
are to the Tax Court Rules of Practice and Procedure. All
(continued...)
T.C. Memo. 2005-258
UNITED STATES TAX COURT
JOYCE M. THOMAS, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10824-03. Filed November 1, 2005.
Joyce M. Thomas, pro se.
Andrew R. Moore
, for respondent.
…
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 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 RulingsApr 11, 2012
s.
On March 5, 1999, Mr. Cline sent to Dr. White a letter regarding his
attendance at the xélan seminar and the need to schedule a meeting to create a xélan tax reduction plan for Dr. White. Dr. White met with Mr. Cline on June 16,
1999, to discuss Dr. White's financial needs and the possibility of joining the
Economic…
IRCCourt RulingsNov 10, 2004★ strong match
…ent’s litigating
position that the distribution occurred in 2000. See Garcia v.
Commissioner
, T.C. Memo. 1998-203 (reaching this conclusion
regarding another question and answer contained in the same
proposed regulation), affd. without published opinion 190 F.3d
538 (5th Cir. 1999). Additionally, the substantially lev…
IRCCourt RulingsJun 3, 1998related by meaning
…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 RulingsMar 31, 2005
siness trips made in taxable year 1999. As to her other
business expenses, petitioner does not know how these expenses
and deductions were calculated. Petitioner was disabled and unable to work from February to
June 1999. While on disability, petitioner spent no time on her
jewelry activity, the Port of Mystery. During…
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…
Rev. Proc. 2021-30 — Rev. Proc. 2021-30 adds two new benefit overpayment correction methods that encourage employers to avoid seeking recoupment of benefit overpayments made to par… IRCRevenue ProceduresModified Aug 2, 2021
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 Earnings, including the $575 for 1999 Earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
Rev. Proc. 2018-52 — The revenue procedure modifies and supersedes Rev. Proc. 2016–51, 2016–42 I.R.B. 465, which sets forth the Employee Plans Compliance Resolution System (“EPCRS”… IRCRevenue ProceduresOct 15, 2018
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 Earnings, including the $575 for 1999 Earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
Rev. Proc. 2016-51 — This revenue procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements o… IRCRevenue ProceduresOct 17, 2016
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 Earnings, including the $575 for 1999 Earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
Rev. Proc. 2008-50 — This procedure updates the comprehensive system of correction programs for sponsors of retirement plans that are intended to satisfy the requirements of sectio… IRCRevenue ProceduresSep 2, 2008
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 earnings, including the $575 for 1999 earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
Rev. Proc. 2006-27 — Administrative programs; correction programs. This procedure updates and expands upon the Service’s comprehensive Employee Plans Compliance Resolution System (… IRCRevenue ProceduresSuperseded May 30, 2006
…ecember 31, 1998, by $5,000.
(c) The resulting December 31, 1998 account balances will share in the 1999 earnings, including the $575 for 1999 earnings included in the corrective contribution ($5,750(.10)), to determine the account balances as of December 31, 1999. However, each account balance other than Employee X’s …
IRCCourt RulingsSep 24, 2007
…01 and were divorced in 2002 .
Petitioner first learned that there were proposed
adjustments to the 1999 tax return when respondent offset a claimed overpayment from her 2001 tax return against a tax
balance due from 1999 .1 The amount remaining unpaid for 1999 a s
of March 2005 was $1,582 .58 .
Petitioner timely reque…
IRCCourt RulingsApr 14, 2005
ee Pension, Deduction on
the 1999 Return, Notice of Deficiency, and Tax Court
Proceedings
On March 10, 2000, petitioner made an $8,638 contribution to her simplified employee pension for 1999. Petitioner calculated
the contribution on the basis of the income she earned under the
personal service contracts.
- 13 -
Petit…