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21. 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…
22. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    …ng given a reasonable opportunity to present such evidence. Id.; see also Giamelli v. Commissioner, 129 T.C. 107, 114-115 (2007). - 17 - [*17] In evaluating a determination by the Office of Appeals after a CDP hearing, the Court's general standard of review for evaluating challenges to the underlying tax liability is d…
23. 108 T.C. No. 5 — George & Elam Campbell v. Commissioner
    IRCCourt RulingsFeb 18, 1997related by meaning
    l section references are to the Internal Revenue Code in effect for 1991, the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 Sec. 4980A imposes a 15-percent excise tax on excess distributions from qualified retirement plans. This tax is included within ch. 43 of the I…
24. 45 T.C. 133 — Jacobs v. Commissioner
    IRCCourt RulingsOct 28, 1965related by meaning
    ifying 16 T.C. 882 (1951), certiorari denied 344 U.S. 874, with Brainard Steel Corporation v. United States, 137 Ct. Cl. 114, 146 F. Supp. 461 (1956). Petitioner argues in the alternative that if Credit, Inc., is denied the deduction in its final taxable period he should be allowed a deduction for (a) amounts actually …
25. T.C. Summary Opinion 2012-119 — John Bruce & Frances H. Corcoran v. Commissioner
    IRCCourt RulingsDec 10, 2012
    …under the plan even if he has only forfeitable rights to those benefits." H.R. Rept. No. 93-807, at 129 (1974), 1974-3 C.B. (Supp.) 236, 364. Section 1.219-2(b),.Income Tax Regs., concerns defined benefit plans and, in particular, states: "[A]n individual is an active participant in a defined benefit plan if for any po…
26. T.C. Memo. 1997-250 — John E. & Concetta Lozon v. Commissioner
    IRCCourt RulingsJun 4, 1997related by meaning
    amount is erroneously treated as self-employment income, or if an amount is erroneously treated as wages, and (2) If the correction of the error would require an assessment of one such tax and the refund or credit of the other tax, and - 23 - (3) If at any time the correction of the error is authorized as to one such t…
27. 88 T.C. 548; 88 T.C. No. 28 — Porter v. Commissioner
    IRCCourt RulingsMar 5, 1987related by meaning
    amended and in effect during the years in issue. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. Our references to secs. 371 and 372 of the Judicial Code are to those sections as in effect during 1980 and 1981. Sec. 372 of the Judicial Code was amended twice by acts…
28. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024
    …Budget Act of 2015.”) ); Bipartisan Budget Act of 2015, Pub. L. No . 114- 74, § 1101(f)(3), (g)(1), 129 Stat. 584, 637 – 38 (“[Amended section 6501(n)] shall apply to returns filed for partnership taxable years beginning after December 31, 2017.”); Surface Transportation and Veterans Health Care Choice Improvement Act …
29. 86 T.C. 980; 86 T.C. No. 60 — Estate of Rosenberg v. Commissioner
    IRCCourt RulingsMay 19, 1986related by meaning
    4); Estate of English v. Commissioner, T.C. Memo. 1985-549, 50 T.C.M. 1362, 54 P-H Memo T.C. par. 85,549. Decision will he entered for the respondent. While the constitutional issue was the only argument raised in the petition with respect to the dispute over inclusion of the lump-sum payment, we deal also with the two…
30. T.C. Memo. 2022-4 — Estate of Anthony K. Washington, Deceased, Lenda Washington, Personal Representative v. Commissioner
    IRCCourt RulingsFeb 2, 2022
    … collection review proceeding, the Court will review the matter de novo. Giamelli v. Commissioner , 129 T.C. 107, 111 (2007); Davis v. Commissioner, 115 T.C. 35, 39 (2000). When (as here) the underlying liability is not pro perly before us, we review the determination for abuse of discretion. Byers v. Commissioner, 740…
31. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    g, we give effect to the plain meaning of the words used therein and sustain respondent's determination that petitioners are liable for the 10-percent additional tax under section 72(t). We have considered petitioners' remaining arguments and find them unpersuasive. 3. Conclusion In order to give effect to our disposit…
32. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    distribution qualified for tax-free rollover treatment under section 402(a)(5); Brown v. Commissioner , T.C. Memo. 1995-93 (same); cf. supra with T.C. Memo. 1993-561. - 13 - 10 It would appear that such stipulation would also affect the amount of the excise tax under sec. 4980A. We leave this matter to the parties as p…
33. 73 T.C. 40 — La Fargue v. Commissioner
    IRCCourt RulingsOct 10, 1979related by meaning
    r Rule 155. Statutory references are to the Internal Revenue Code of 1954, as amended and effective in the years in issue, unless otherwise indicated. Petitioner’s constitutional claim was originally presented in the form of a motion for summary judgment, but with leave of the Court, the motion was withdrawn by petitio…
34. 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…
35. 86 FR 2541 — Adjustment of Civil Penalties for Inflation
    PBGCFinal Rules (FR)Jan 13, 2021
    …ntinues to read as follows: Authority: 28 U.S.C. 2461 note, as amended by sec. 701, Pub. L. 114-74, 129 Stat. 599-601; 29 U.S.C. 1302(b)(3), 1371. § 4071.3 [Amended] 2. In § 4071.3, the figures “$2,233” are removed and the figures “$2,259” are added in their place. PART 4302—PENALTIES FOR FAILURE TO PROVIDE CERTAIN MUL…
36. 83 T.C. 132; 83 T.C. No. 9 — Boggs v. Commissioner
    IRCCourt RulingsJul 24, 1984related by meaning
    rectly involved in such ruling. * * *” See also Rev. Proc. 67-1, 1967-1 C.B. 544; Rev. Proc. 72-3, 1972-1 C.B. 698; Rev. Proc. 80-24, 1980-1 C.B. 658. See Judge Chabot’s dissenting opinion in Woodson v. Commissioner, 73 T.C. 779,786,791 (1980), where it was suggested that the majority opinion therein could possibly be …
37. 131 T.C. No. 12 — Mary Ann Kollar v. Commissioner
    IRCCourt RulingsNov 25, 2008
    …s used in TRHCA section 408(c) includes the accrued interest at hand . See Leahy v . Commissioner , 129 T .C . 71, 72 & n .3 (2007) (stating that the reference in section 7463(f)(2) to the word "tax" includes interest and penalties on account of sections 6601(e)(1) and 6665(a)) ; Petrane v . Commissioner , 129 T .C . 1…
38. 82 T.C. 152; 82 T.C. No. 14 — Baetens v. Commissioner
    IRCCourt RulingsJan 26, 1984related by meaning
    shall not apply to amounts described in clause (ii) of subparagraph (A) of section 72(mX5) to the extent that section 72(mX5) applies to such amounts. (J) Unrealized appreciation op employer securities. — In the case of any distribution including securities of the employer corporation which, without regard to the requi…
39. T.C. Memo. 2025-99 — Middle Department Inspection Agency, Inc. v. Commissioner
    IRCCourt RulingsOct 1, 2025
    lli v. Commissioner, 129 T.C. 107, 111 (2007); Murphy v. Commissioner, 125 T.C. 301, 308, 320 (2005) , aff’d , 469 F.3d 27 (1st Cir. 2006) . Where the underlying tax liability was properly at issue in the CDP hearing, we will review the determination de novo. Lunsford v. Commissioner, 117 T.C. 183, 185 (2001) (citing G…
40. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999related by meaning
    T.C. Memo. 1999-4 UNITED STATES TAX COURT THOMAS MARK PEASLEE, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8582-97. Filed January 13, 1999. Thomas Mark Peaslee, pro se. James A. Whitten , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOLDBERG, Special Trial Judge : This case was hea…