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70 documents · 0.17sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJan 17, 2024related by meaning
    Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure . Served 01/17/24 2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of $8,476,705 . The notices also determined additions to tax under section 6651(a)(1) and (2) and accurac…
  2. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    T .C . Memo . 2007-292 UNITED STATES TAX COUR T HUBERT JOUBERT, Petitioner V . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 8769-06 . Filed September 24, 2007 . P failed to file a Federal income tax return for 2002 . R determined a deficiency and asserted in the notic e deficiency, the answer, and the pret…
  3. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    4, 2011, but was continued on petitioners' motion so that the parties could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on petitioners' motion so that they could take a trip out of the country. By notice served May 9, 201…
  4. 97 T.C. 237; 97 T.C. No. 14 — Guilzon v. Commissioner
    IRCCourt RulingsAug 6, 1991related by meaning
    f the matter is that the payment in question should be taxable to petitioner under section 72(e). Accordingly, we sustain respondent’s determination.6 In order to take into account what appear to be mechanical errors in respondent’s calculations and to afford the parties a further opportunity to resolve the question of…
  5. T.C. Memo. 2014-31 — K.H. Company, LLC Employee Stock Ownership Plan v. Commissioner
    IRCCourt RulingsFeb 24, 2014
    …ral or directory and does not relate to the essence of the statute. Taylor v. Commissioner, 67 T.C. 1071, 1077-1078 (1977).
  6. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…
  7. T.C. Memo. 2017-67 — Sean M. Murray v. Commissioner
    IRCCourt RulingsApr 20, 2017
    …, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwhiler v. Commissioner, T.C. Memo. 2016-18, 111 T.C.M. (CCH) 1071, 1074. Petitioner has repeatedly advanced numerous frivolous positions in this
  8. 105 T.C. 141; 105 T.C. No. 12 — Brotman v. Commissioner
    IRCCourt RulingsAug 24, 1995related by meaning
    OPINION Tannenwald, Judge: Respondent determined a deficiency in petitioner’s 1988 Federal income tax of $11,752 and an addition to tax of $588 under section 6653(a)(1). This case is before us on respondent’s motion for partial summary judgment under Rule 121 that collateral estoppel precludes petitioner’s claim that a…
  9. T.C. Memo. 2012-166 — Todd R. & Andrea Pedersen v. Commissioner
    IRCCourt RulingsJun 13, 2012
    …td. v. United States, 291 F.2d 761, 768 (9th Cir. 1961)), aff'd without published opinion, 770 F.2d 1071 (3d Cir. 1985); see also House Beautiful Homes, Inc. v. Commissioner, 405 F.2d at 66 ("[I]t is only through an analysis of conduct that motivation can be inferred. Whether the conduct occurs immediately subsequent t…
  10. T.C. Memo. 2007-343 — Ramzy M. & Lena Kopty v. Commissioner
    IRCCourt RulingsNov 21, 2007
    …93 36 .1085 6,818 .47 1,608 .94 8,427 .4 1 1994 66 .0084 15,698 .12 1,725 .72 17,423 .8 4 1995 108 .1071 46,776 .86 6 .29 46,783 .1 5 1996 144 .5164 108,732 .69 30 .90 108,763 .5 9 1996 110,116 .148 0 1997 10,323 .9064 304,555 .24 10 .31 304,565 .5 5 'Number of shares restated to reflect a 70-to-1 stock split . After p…
  11. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  12. T.C. Memo. 2003-194 — Edward A. Bougas, III v. Commissioner
    IRCCourt RulingsJul 2, 2003
    …ubstance or essence of the statute, they must be rigidly observed. Taylor v. Commissioner , 67 T.C. 1071, 1077 (1977); Sperapani v. Commissioner , 42 T.C. 308, 331 (1964). On the other hand, if the requirements are procedural or directory in that they do not go to the essence of the thing to be done, but rather - 8 - a…
  13. T.C. Memo. 2003-32 — Howard E. Clendenen v. Commissioner
    IRCCourt RulingsFeb 12, 2003
    …ommissioner , T.C. Memo. 1998-318 (docket No. 18155-96R) (the declaratory judgment), affd. 207 F.3d 1071 (8th Cir. 2000). We held that the trust was not a qualified trust under section 401(a) beginning with the plan year 1986 because the annual additions exceeded the limitations of section 415(c) when we found that the…
  14. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019
    …r, 791 F.2d 68, 71 (7th Cir. 1986); Bruhwiler v. Commissioner, T.C. Memo. 2016-18, 111 T.C.M. (CCH) 1071, 1074. Petitioner has raised many frivolous arguments during this litigation. We sanctioned him on two prior occasions for advancing frivolous arguments, and in this case we repeatedly warned him to desist from doin…
  15. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    or the taxing authority that imposed the levy. Petitioners have not shown that they are eligible for the exception for tax levies under section 72(t). Petitioners also contend that the remaining portion of the $17,500 was a loan which they used to purchase a home in Vermont in 2013. Petitioners provided only Form 1099-…
  16. T.C. Memo. 2025-7 — Sonji Marie Mosley v. Commissioner
    IRCCourt RulingsJan 22, 2025
    …dler v. Commissioner, 75 T.C. 1, 20– 21 ( 1980) ( quoting Es tate of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960)). Petitioner has not argued that any of the statutory exceptions under section 6654(e) applies , and none apply . Accordingly, we find that petitioner is liable for the addition to tax under section 665…
  17. T.C. Memo. 2000-171 — Van Roekel Farms, Inc. v. Commissioner
    IRCCourt RulingsMay 24, 2000
    …dependent contractor working for the taxpayer, Howard E. Clendenen, Inc. v. Commissioner , 207 F.3d 1071 (8th Cir. 2000), affg. T.C. Memo. 1998-318. We follow that holding and conclude that the management fees paid to Mr.
  18. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    470 in petitioner's deductions, a $144 decrease in petitioner's withholding credits, and the imposition of the section 72(t) additional tax of $1,283. Petitioner timely filed a Form 8857, Request for Innocent Spolse Relief, seeking equitable relief from liability under the provisions of section 66(c). Respondent determ…
  19. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
    IRCCourt RulingsAug 28, 2008
    … . Commissioner , 75 T .C . 1, 20-21 (1980) ; see also Estate of Ruben v . Commissioner , 33 T .C . 1071, 1072 (1960) (reasonable cause and lack of willful neglect are not relevant considerations for estimated tax addition) . Notwithstanding the lack of reasonable cause, respondent must produce evidence sufficient for …
  20. T.C. Memo. 2024-24 — James Elbert Aldridge, Jr. & Shirley Lorraine Aldridge v. Commissioner
    IRCCourt RulingsFeb 21, 2024
    …g in part T.C. Memo. 202073; Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner , 29 F.4th 1066, 1071– 74 (9th Cir. 2022), rev’g and remanding 154 T.C. 68 (2020). The Eight Circuit, to which an appeal in this case would presumably lie, see supra note 3, has not squarely addressed the test for determining compliance …