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1. T.C. Summary Opinion 2007-180 — Suzanne E. Barrera, a.k.a. Suzanne E. Battle v. Commissioner
   IRCCourt RulingsOct 24, 2007
   …rrera’s signature. The 1998 return bears an IRS stamp showing it was received by the IRS on May 30, 2000. The joint return for taxable year 1999 shows a typed date of “11-02-00” next to the signature of the paid return preparer. - 12 - The 1999 return also shows a typed date of “11-02-00” next to both petitioner’s and …
2. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
   IRCCourt RulingsNov 21, 2007
   …ng 10 .6 METS . Subsequently, Mr . Kopty was admitted to the American Hospital in Dubai on March 3, 2000, with the symptoms of a heart attack . Approximately 2 weeks later he was transported to the Universite Catholique De Louvain Cliniques Universitaires SaintLuc, a hospital in Belgium, where he underwent coronary byp…
3. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
   IRCCourt RulingsJul 13, 2010
   …Barn Actors studio during 2001 and 2002 . Neither petitioner was employed by any third party during 2000, 2001, or 2002 . Petitioners did not file a timely .tax return for the 2000, 2001, or 2002 tax years . Mr . O'Boyle paid $10,000 toward his potential Federal income tax liability for the 2000 tax year . At the time …
4. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
   IRCCourt RulingsApr 2, 2020related by meaning
   mediary period: September 26-28, 2008. . . . . . . . . . . . . . . . . . 99 Q. Period 11: September 29 through November 13, 2008 . . . . . . . . . 100 1. Introduction...................................... 100 2. Events .......................................... 100 3. Analysis and holding...............................…
5. T.C. Memo. 2007-19 — Bidyut K. & Diana T. Bhattacharyya v. Commissioner
   IRCCourt RulingsJan 30, 2007
   …Fidelity IRA. Fidelity Institutional issued petitioner a Form 1099-R with respect to Plan 15106 for 2000 (the Plan 15106 Form 1099-R). The parties stipulated that the Plan 15106 Form 1099-R accurately reflected the offsetting distribution made in satisfaction of the loan and the direct rollover into the Fidelity IRA, i…
6. T.C. Memo. 2009-272 — Carolyn D. Hemrick v. Commissioner
   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 .…
7. T.C. Memo. 2007-48 — Diana Van Arsdalen, f.k.a. Diana Murray, Petitioner, and Stanley David Murray, Intervenor v. Commissioner
   IRCCourt RulingsMar 5, 2007
   . 2000-15, sec. 4, 2000-1 C.B. 447, 448-449, that the Commissioner considers in determining whether to grant equitable relief under section 6015(f). 4 First, the Commissioner will not grant relief - 9 - unless seven threshold conditions have been met: (1) The taxpayer must have filed joint returns for the taxable years…
8. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
   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…
9. T.C. Memo. 1997-277 — Margaret M. Merker v. Commissioner
   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…
10. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004
    termined that Mr. and Mrs. Molina properly reported the $19,620 distribution on - 5 - their 2000 return and that they had sufficient income and assets to pay their 2000 tax liability in full. Respondent rejected the OIC, concluding there was no doubt as to liability or collectibility. In the petition, under the stateme…
11. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    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))…
12. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    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 (…
13. T.C. Memo. 2011-92 — Kathleen Susan Stipe v. Commissioner
    IRCCourt RulingsApr 25, 2011related by meaning
    under section 72(t) for an early distribution from a qualified retirement plan in 2005.' 'The 10-percent additional tax applies only to the TSP loans that petitioner failed to repay. Respondent did not assert in (continued...) - 11 - IV. Conclusion In summary, we conclude that (1) petitioner received taxable disability…
14. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    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…
15. 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
    or documents to which § 6104 (document open to public inspection) applies, as described in section 10.03. Taxpayer may protest deletions not made .05 After receiving the notice under § 6110(f)(1) of intention to disclose the TAM, the taxpayer may protest the disclosure of certain information in it. The taxpayer must s…
16. T.C. Memo. 2010-226 — Harry Eugene Mathews v. Commissioner
    IRCCourt RulingsOct 19, 2010related by meaning
    … • warnings that he was in danger of being penalized. For example, in Mathews v. Commissioner, T.C. Memo. 2005-84, we told petitioner: "Even though the filing of the petition resulted in respondent's concession of the sec. 72(t) additional tax,
17. 137 T.C. No. 2 — Robert K. & Joan L. Paschall v. Commissioner
    IRCCourt RulingsJul 5, 2011
    …rved as president, secretary, and treasurer of both corporations during all relevant periods." "For 2000 and 2001, West Star filed Forms 1120, U.S. Corporation Income Tax Return, reporting zero gross receipts and zero deductions for each year. West Star reported assets of $2,000 cash as of Dec. 31, 2000, and assets of …
18. Treas. Reg. § 1.432(e)(9)-1(d)(6)(v) — Benefit suspensions for multiemployer plans in critical and declining status.
    IRCRegulationsSep 9, 2016
    participants who had service only after January 1, 2000, and participants who had service during both of those periods. The suspension of benefits provides for different treatment for different participants and beneficiaries (other than as a result of application of the individual limitations). In addition, the suspens…
19. 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.…
20. 162 T.C. No. 7 — Mohamed K. Abdo & Fardowsa J. Farah v. Commissioner
    IRCCourt RulingsApr 2, 2024related by meaning
    is extended. See Stromme v. Commissioner, 138 T.C. 213, 218 n.8 (2012). We note, however, that effective with respect to federal ly declared disasters declared after November 15, 2021, the extension period has been redefined to end “on the date which is 60 days after the later of . . . [the] earliest incident date . . …