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21. T.C. Summary Opinion 2005-10 — Jerome P. & Rhonda A. Reimann v. Commissioner
    IRCCourt RulingsJan 27, 2005
    …ble and ordinarily prudent person would do under the circumstances. Neely v. Commissioner , 85 T.C. 934, 947 (1985). Under section 6664(c), no penalty shall be imposed under section 6662(a) with respect to any portion of an underpayment if it is shown that there was a reasonable cause for such portion and that the taxp…
22. 59 T.C. 598; 59 T.C. No. 59 — Thriftimart, Inc. v. Commissioner
    IRCCourt RulingsJan 31, 1973related by meaning
    for any payment of any specific amount to any employee until the conditions of that employee having medical services or being away from work occurred. In Simplified Tax Records, Inc., 41 T.C. 75, 79 (1963), in disallowing a deduction to the taxpayer for a reserve for the estimated future cost of preparing subscribers’ …
23. T.C. Memo. 1998-203 — Ramon A. & Bertha E. Garcia v. Commissioner
    IRCCourt RulingsJun 3, 1998
    …circumstances. See Rybak v. Commissioner , 91 T.C. 524, 565 (1988); Neely v. Commissioner , 85 T.C. 934,
24. T.C. Memo. 2000-137 — Alton F. Emerson v. Commissioner
    IRCCourt RulingsApr 12, 2000
    …and ordinarily prudent person would do under the circumstances. See Neely v. Commissioner , 85 T.C. 934, 947 (1985). The term "disregard" includes any careless, reckless, or intentional disregard. Sec. 6662(c). No penalty shall be imposed if it is shown that there was reasonable cause for such portion of the - 19 -
25. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …03, and ending January 31, 2004, Bevco reported gross receipts of $719,537 and total assets of $610,934. On a 2004 Form 1120 for a year beginning February 1, 2004, and ending January 31, 2005, Bevco reported gross receipts of $680,000 and total assets of $242,919.5 Petitioner's Forms 1040, U.S. Individual Income Tax Re…
26. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995related by meaning
    T.C. Memo. 1995-469 UNITED STATES TAX COURT C. MERRITT and DOROTHY PUMPHREY, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13538-94. Filed October 3, 1995. Jay Fred Cohen , for petitioners. Alan R. Peregoy , for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION DAWSON, Judge : This case was …
27. T.C. Memo. 1998-47 — William Spencer & Barbara Ruth Bach v. Commissioner
    IRCCourt RulingsFeb 5, 1998
    …ioner , 979 F.2d 66, 71 (5th Cir. 1992), affg. T.C. Memo. 1991-510; Neely v. Commissioner , 85 T.C. 934, 947 (1985). Respondent made numerous adjustments to petitioners' income and deductions for 1987. Petitioners have not presented any evidence either at trial or on brief to convince us that their omissions from gross…
28. 66 T.C. 348 — Comprehensive Designers International, Ltd. v. Commissioner
    IRCCourt RulingsMay 26, 1976related by meaning
    s less than the dollar amount accrued, the foreign tax credit for the year in question should be correspondingly adjusted. We hold for the respondent. Initially, we note that the Code encompasses a system of taxation in respect of income of United States persons and of income of non-United States persons from sources w…
29. 114 T.C. No. 17 — Michael G. Bunney v. Commissioner
    IRCCourt RulingsApr 10, 2000
    …ommissioner , 92 T.C. 1 (1989), affd. 925 F.2d 348 (9th Cir. 1991); Neely v. Commissioner , 85 T.C. 934, 947 (1985). The negligence accuracy-related penalty is inapplicable to any portion of an underpayment to the extent that an individual has reasonable cause for that portion and acts in good faith with respect theret…
30. 70 T.C. 788 — 212 Corp. v. Commissioner
    IRCCourt RulingsAug 31, 1978related by meaning
    41), cert. denied 314 U.S. 621 (1941); see also sec. 1.170-l(c), Income Tax Regs.; sec. 20.2031-1(b), Estate Tax Regs.; sec. 25.2512-1, Gift Tax Regs. The petitioners argue that the parties agreed upon a value of $225,000 for the properties and that this Court is bound to respect the value contractually agreed upon by …
31. T.C. Memo. 2017-22 — Kevin Cheves & Jennifer Cheves v. Commissioner
    IRCCourt RulingsJan 30, 2017
    …able and ordinarily prudent person would do under the circumstances. Neely v. Commissioner, 85 T.C. 934, 947 (1985). It is also a failure to reasonably attempt to comply with the Internal Revenue Code. Sec. 6662(c). However, section 6662(c) provides that no penalty shall be imposed with respect to any portion of an und…
32. T.C. Memo. 2002-17 — Angela C. Morris v. Commissioner
    IRCCourt RulingsJan 16, 2002related by meaning
    cts and circumstances, it is inequitable to hold the individual liable for any unpaid tax or any deficiency (or any portion of either) attributable to any item for which relief is not available under the preceding sentence, the Secretary may relieve such individual of such liability. . Petitioner's request for relief r…
33. 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…
34. T.C. Memo. 2005-124 — Henry Uscinski and Jacqueline Uscinski v. Commissioner
    IRCCourt RulingsMay 25, 2005related by meaning
    s to expedite litigation and avoid the expense of unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (1988). A motion for summary judgment may be granted where there is no dispute as to a material fact and a decision may be rendered as a matter of law. See Rule 121. The moving party bears the burde…
35. T.C. Memo. 2008-93 — Blake Sime & Susan M. Atkin v. Commissioner
    IRCCourt RulingsApr 10, 2008
    … .C . 1, 12 (1989), affd . 925 F .2d 348, 353 (9th Cir . 1991) ; Neely v . Commissioner , 85 T .C . 934, 947 (1985) . The term "disregard" includes any careless, reckless, or intentional disregard . Sec . 6662(c) . The term "understatement" means the excess of the amount of tax required to be shown on a return over the…
36. T.C. Memo. 2014-31 — K.H. Company, LLC Employee Stock Ownership Plan v. Commissioner
    IRCCourt RulingsFeb 24, 2014
    …1) made or otherwise referred to section 132(f)(4). Rev. Proc. 2002-73, sec. 5.01, 2002-2 C.B. 932, 934, extended the time for amending a plan to comply with the CRA to the latest of the end of the first plan year beginning on or after January 1, 2002, the end of the plan's GUST remedial amendment period, or June 30, 2…
37. T.C. Memo. 2005-298 — Isabelle Bichindaritz v. Commissioner
    IRCCourt RulingsDec 29, 2005related by meaning
    d the $1,916 payment as a qualified retirement contribution to an individual retirement account (IRA). She contended in her pretrial memorandum and at trial that she properly deducted that amount as an IRA contribution. In the opening brief, respondent argued that section 219(g)(5) limits IRA deductions for active part…
38. 113 T.C. No. 9 — Sklar, Greenstein & Scheer, P.C. v. Commissioner
    IRCCourt RulingsAug 13, 1999
    …oner , 92 T.C. 1 (1989), affd. 925 F.2d 348 - 17 - (9th Cir. 1991); Neely v. Commissioner , 85 T.C. 934, 947 (1985). The accuracy-related penalty of section 6662 is not applicable to any portion of an underpayment to the extent that an individual has reasonable cause for that portion and acts in good faith with respect…
39. 105 T.C. 16; 105 T.C. No. 2 — Snap-Drape v. Commissioner
    IRCCourt RulingsJul 13, 1995related by meaning
    ere the detriment is very severe. Beneficial Life Ins. Co. v. Commissioner, 79 T.C. 627, 642 (1982); see also CWT Farms, Inc. v. Commissioner, 79 T.C. 1054, 1068-1069 (1982) (retroactive application of a regulation was sustained where the taxpayer unjustifiably relied on a handbook published by respondent for guidance)…
40. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019
    …he taxpayer's records for purposes of § 1.60011(a). Notice 2009-41, sec. 3.02(2), 2009-19 I.R.B. at 934. However, the AHRI certificate is not a manufacturer's certificate because it specifically lists the manufacturers for the outdoor and indoor components as "York, Unitary Products Group" and "Advanced Distributor Pro…