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21. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    which is defined by the Internal Revenue Code. See section 6211(a). As relevant - 9 - herein, a deficiency is the amount of income tax imposed by the Internal Revenue Code that exceeds the amount shown as the tax by the taxpayer on his return (if a return was filed). Thus, payments made by a taxpayer, such as the $750 …
22. T.C. Memo. 2019-128 — Claude Tate George v. Commissioner
    IRCCourt RulingsSep 25, 2019related by meaning
    section 6651(a)(1) and (2), respectively.¹ Respondent has moved for summary adjudication in his favor on all issues (motion), and petitioner objects. Summary judgment is appropriate "if the pleadings, answers to interrogatories, depositions, admissions, and any other acceptable materials, together with the affidavits …
23. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …rk Trust): 1989 1990 Tax-exempt income $10,905 $64,477 Total income-0 - - 0 - Fiduciary fees 500 10,623 Total deductions-0 - - 0 - Taxable income-0 - - 0 - Total tax-0 - - 0 - Security Pacific filed 1990 through 1994 Forms 1041 that reported the following items of income and expense for the Trust, listed - 34 - 10 We a…
24. 62 T.C. 524; 62 T.C. No. 59 — Estate of Harrison v. Commissioner
    IRCCourt RulingsJul 25, 1974related by meaning
    ew principal place of work. Prior to Jan. 1, 1970, self-employed persons were not entitled to the benefits of sec. 217. SEC. 6653. FAILURE TO PAY TAX. (a) Negligence ok Intentional Disregard of Roles and Regulations With Respect to Income or Gift Taxes. — If any part of any underpayment (as defined in subsection (c) (1…
25. T.C. Summary Opinion 2002-33 — Wallace F. & Mi-Ja H. Smith v. Commissioner
    IRCCourt RulingsApr 3, 2002
    …U. of California Benefits Program Distribution Pension Plan $61,378.13 Defined Contribution Plan 12,623.61 Capital Accumulation Provision Account 14,207.14 Total $88,208.88 Petitioner also received a distribution of $11,281 from an IRA at Bank of America during 1997. On their Federal income tax return for 1997, petitio…
26. T.C. Memo. 2010-142 — Ronald W. Parkinson v. Commissioner
    IRCCourt RulingsJun 28, 2010related by meaning
    a reasonable .dispute with respect to any item of income reported on an information return filed with the Secretary by a third party :and the taxpayer has "fully cooperated with the Secretary (including providing,,-, within ,a reasonable period-of time, access to and inspection of, all witnesses, information, and docum…
27. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    but did not." Central Tablet Manufacturing Co. v. United States , 417 U.S. 673, 690 (1974); Commissioner v. National Alfalfa Dehydrating & Milling Co. , 417 U.S. 134, 148-149 (1974). It would be quite intolerable to pyramid the existing complexities of tax law by a rule that the tax shall be that resulting from the for…
28. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997
    …2,302 Hartford Life Insurance Co. Compensation 677 State Employees Credit Union IRA distribution 25,623 State Employees Credit Union Interest 493 Susan W. Cujas Payor Type of Payment Amount Northwest Child Development Council, Inc. Compensation $4,702 The Investment Company of America Dividends 95 State Employees Credi…
29. 136 T.C. No. 2 — G. Mason Cadwell, Jr. v. Commissioner
    IRCCourt RulingsJan 3, 2011related by meaning
    ce 2002-8 supra,-are unrêasonable or incorrect. Furthermore, on a motion f r summary judgm t thàt is prð];>erly'm de and supported, the o poeing party must 9et forth specific facts showing that there is a genuine issue fo trial. Rule 121(d) . Petitioner does not allege thathe has any evidence that wo ld sat-isfy 'that …
30. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
31. 74 T.C. 808; 2 Employee Benefits Cas. (BNA) 2071 — Engineered Timber Sales, Inc. v. Commissioner
    IRCCourt RulingsJul 22, 1980
    …resent beneficial ownership. See, e.g., Tatum Bros. Real Estate & Investment Co. v. Watson, 109 So. 623 (Fla. 1926). In 1974, none of the ETS employees had acquired a beneficial ownership interest in any portion of the $16,123 that petitioner placed in the trust’s account at the Landmark Bank of Tampa. Aside from any c…
32. T.C. Memo. 2005-258 — Joyce M. Thomas v. Commissioner
    IRCCourt RulingsNov 1, 2005related by meaning
    bilateral tendinitis, carpal tunnel syndrome, and depression at the time the estimated payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own startup network marketing business. We find that petitioner was not disabled for purposes of section 6654. The…
33. 131 T.C. No. 15 — Larry G. & Maria A. Walton Mitchell v. Commissioner
    IRCCourt RulingsDec 15, 2008
    … whether initial factual determinations were correctly made.” Arizona v. California , 460 U.S. 605, 623-24 (1983). The second counterexample--though flowing from the same spring of judicial desire for finality and consistency--is closer to what we have here. In the old case of Johnson Co. v. Wharton, Jr., & Co. , 152 U…
34. T.C. Summary Opinion 2012-74 — Charles Grant & Elizabeth A. Beech v. Commissioner
    IRCCourt RulingsJul 26, 2012
    …propriate. The judiciary is not authorized to redraw the boundaries." Kim v. Commissioner, 579 F.3d 623, 625-626 (7th Cir. 2012), afg T.C. Dkt. No. 11902-10 (May 20, 2011) (bench opinion).
35. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    5. Unless indicated otherwise, all section references are to sections of the Internal Revenue Code of 1954 as in effect for the taxable year in issue. Since respondent asserts that no return was filed by petitioners, respondent asserts a deficiency in the full amount of the asserted income tax liability (sec. 6211) and…
36. T.C. Memo. 2006-72 — Stephen Daryl Royal v. Commissioner
    IRCCourt RulingsApr 11, 2006
    …come that equals or exceeds $33,178. See sec. 32(b)(1)(A) änd (2);. Rev. Proc. 2001-59, 2001-2 C.B. 623, 625626. In petitioner's 2002 return, petitioner claimed adjusted gross income of $24,284.22. We have held that petitioner must 042 include $25,940.49 in his gross income for 2002. As a result, petitioner's adjusted …
37. U.S. Tax Court — Michael K. Billups v. Commissioner
    IRCCourt RulingsJun 1, 2009related by meaning
    account of the employee's disability ; (4) as part of a serie s e for life ; (5) to a employee after separation from service after attainment of ag A substantially equal periodic payments m 55 ; (6) as dividends paid with, respect to corporate stoc k described in section 404(k) ; (7) to an employee for medica l or (8)…
38. T.C. Memo. 2004-51 — Meleca Vulic v. Commissioner
    IRCCourt RulingsMar 8, 2004
    …ent determined a deficiency of $8,117 and an accuracy-related penalty under section 6662(a) 1 of $1,623 in petitioner’s Federal income tax for 2000 (year in issue). The issues for decision are: (1) Whether petitioner is liable for a - 2 - 10-percent additional tax on an early distribution from a qualified retirement pl…
39. T.C. Memo. 1996-404 — Leonard A. Gross v. Commissioner
    IRCCourt RulingsAug 28, 1996related by meaning
    ented are contained in pleadings and other documents in the record, and are not controverted. We must consider whether respondent was entitled to mail petitioner a second notice of deficiency concerning petitioner's 1991 taxable year. If respondent was not entitled to do so, then the August notice would not be valid as…
40. T.C. Memo. 1998-30 — Brian J. Patrick v. Commissioner
    IRCCourt RulingsJan 26, 1998
    …14,000. The monthly installments, including interest, for Wayne's 1992 and 1993 "loans" totaled $13,623.08. In 1992 through 1994, Wayne received wages, interest and dividend income totaling $13,439, $45,359, and $57,352, respectively. Petitioners' inability, ab initio, to meet their contractual obligation to service th…