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Go to 57 T.C. 469 (not yet in the library — opens the official source)
79 documents · 0.20sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
  2. T.C. Memo. 2026-33 — Jonathan D. Sawyer v. Commissioner
    IRCCourt RulingsApr 16, 2026
    … investment ” shall include — (i) any property which produces income of a type described in section 469(e)(1), and (ii) any interest held by a taxpayer in an activity involving the conduct of a trade or business— (I) which is not a passive activity, and (II) with respect to which the taxpayer does not materially partic…
  3. T.C. Summary Opinion 2001-148 — Patrick L. O'Brien v. Commissioner
    IRCCourt RulingsSep 21, 2001
    …stribution of a rounded amount of $27,846 from an employee stock ownership plan, for a total of $79,469. Hereinafter, both distributions will be referred to as one distribution. On his 1997 Federal income tax return, petitioner reported that $37,848 of the $79,469 distribution was taxable. Respondent determined that th…
  4. IRCCourt RulingsAug 3, 1979related by meaning
    Chabot, Judge: Respondent determined deficiencies in petitioners’ Federal income tax and in excise tax under section 4973(a) for 1975, as follows: Deficiencies in— Docket No. Petitioners Income tax gi 6173-77 John L. Guest .$437.60 9115-77 James Ventresca and Jordy L. Ventresca . 296.00 Jerome Kobos . 286.18 Edward And…
  5. 85 FR 71142 — Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency
    IRCFinal Rules (FR)Nov 6, 2020
    …del already provides for separate quality adjusted target prices for hip fracture cases for MS-DRGs 469 and 470. Multiple commenters stated their belief that there is value in maintaining hip fracture cases in the CJR model, including that it is administratively simpler and that maintaining hip fractures in the CJR mod…
  6. T.C. Memo. 2013-42 — Roger Phillips v. Commissioner
    IRCCourt RulingsFeb 7, 2013
    …such failure is due to reasonable cause and not due to willful neglect. See United States v. Boyle, 469 U.S. 241, 245 (1985); United States v. Nordbrock, 38 F.3d 440, 444 (9th Cir. 1994). Failure to timely file a Federal income tax return is due to reasonable cause if the taxpayer exercised ordinary business care and p…
  7. T.C. Memo. 1999-289 — Richard David Czepiel v. Commissioner
    IRCCourt RulingsAug 30, 1999related by meaning
    in effect ordered him to satisfy the increased amount awarded to Ms. Czepiel by making the IRA distributions since the only funds available to him in January 1995 to pay that amount consisted of approximately $33,000 on deposit in his IRA's. Respondent counters that the divorce judgment is not a QDRO and that petition…
  8. T.C. Memo. 1995-469 — C. Merritt & Dorothy Pumphrey v. Commissioner
    IRCCourt RulingsOct 3, 1995
    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 …
  9. 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 …
  10. T.D. 9223 — Final regulations under section 402 of the Code address the amount includible in a distributee’s income when life insurance contracts are distributed by a qual…
    IRCTreasury DecisionsSep 26, 2005
    …n, or with reference to, July 31, 2005. Rev. Rul. 2005-64 Rev. Rul. 2005-64 Interaction of sections 469 and 4261. This ruling describes the circumstances in which losses incurred by an individual who provides air transportation through a passthrough entity can qualify as passive losses under section 469 of the Code. In…
  11. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020
    …id not result from willful neglect and (2) was due to reasonable cause. See United States v. Boyle, 469 U.S. 241, 245-246 (1985); Crocker v. Commissioner, 92 T.C. 899, 912-913 (1989); sec. 301.6651-1(c)(1), Proced. & Admin. Regs. Willful neglect has been defined as a "conscious, intentional failure or reckless indiffer…
  12. T.C. Summary Opinion 2002-152 — Sanford M. & Sally Kirshenbaum v. Commissioner
    IRCCourt RulingsNov 25, 2002related by meaning
    (c)(2). Thus, we sustain respondent’s determination on this issue. C. Petitioner’s IRA Deductions As a preliminary matter, we note that deductions are strictly a matter of legislative grace, and a taxpayer bears the burden of proving his or her entitlement to the claimed deductions. 18 Rule 142(a)(1); see New Colonial …
  13. Treas. Reg. § 1.72-5(b)(7) — Expected return.
    IRCRegulationsJul 26, 2016
    …(2), A had died at the end of the fifth year, in the sixth year B would have received a payment of $469.80 (that portion of the $626.40 that A would have received which is in the same ratio that 6 units bear to 8 units) and would thus have received $246.60 less than the portion of the investment in the contract origina…
  14. T.C. Memo. 2020-1 — Clark J. Gebman & Rebecca Gebman v. Commissioner
    IRCCourt RulingsJan 2, 2020related by meaning
    relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are rounded to the nearest dollar. 2Petitioners conceded that they were not entitled to exclude from gross income rental income of $4,920 they received in 2007. - 3 - [*3] to deduct a net operating loss (…
  15. T.C. Memo. 1996-263 — Richard J. & Adele S. Montgomery v. Commissioner
    IRCCourt RulingsJun 11, 1996related by meaning
    rary purpose has been shown here. Because we are satisfied that our analysis of section 4980A(e)(2) leads to the conclusion that the Retirement System was a qualified employer plan under section 4980A, we sustain respondent's determination that petitioner is liable for the 15percent excise tax under section 4980A. - 11…
  16. T.C. Memo. 2015-244 — Jeremiah J. O'Connor & Mary K. O'Connor v. Commissioner
    IRCCourt RulingsDec 16, 2015
    … a , 299 F.3d 221 (3d Cir. 2002); sec. 1.6664-4(b)(1), Income Tax Regs.; cf United States v. Boyle, 469 - 31 - [*31] U.S. 241, 251 (1985). A taxpayer may rely on the advice of any tax adviser, lawyer, or accountant. See Boyle, 469 U.S. at 251. Reliance on a professional tax adviser will not be considered reasonable, ho…
  17. T.C. Memo. 1996-435 — MIT 85; Bryen & Bryen, P.A., Tax Matters Partner v. Commissioner
    IRCCourt RulingsSep 25, 1996
    …. Commissioner , T.C. Memo. 1988-570).] See, in this regard, Foxman v. Commissioner , 352 F.2d 466, 469 (3d Cir. 1965), affg. 41 T.C. 535 (1964); see also Weller v. Commissioner , 270 F.2d 294, 296 (3d Cir. 1959)(quoting Gregory v. Helvering , 293 U.S. 465, 469 (1935)), affg. 31 T.C. 33 and Emmons v. Commissioner , 31 …
  18. T.C. Memo. 2011-62 — Christy & Swan Profit Sharing Plan v. Commissioner
    IRCCourt RulingsMar 15, 2011related by meaning
    ner, T.C. Memo. 2005-70. Section 401(a) sets forth the requirements that must be met by a trust forming part of a profit-sharing plan in order for the trust to be eligible for favorable -tax treatment. Section 7476(a) confers jurisdiction on this Court to issue declaratory judgments as to the initial and continuing qua…
  19. T.C. Memo. 2012-94 — Child Adult Intervention Services, Inc. v. Commissioner
    IRCCourt RulingsMar 28, 2012
    …s. Reliance on an agent does not constitute reasonable cause for failure to timely file. See Boyle, 469 U.S. at 252; Alton OB-Gyn, Ltd. v. United States, 789 F.2d 515, 516 (7th Cir. 1986). 4Although United States v. Boyle, 469 U.S. 241 (1985), involved the delinquent filing of an estate tax return, its principles apply…
  20. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976
    … 1968_ 72,735 72,735.00 1969_ 75,702 75,702.00 1970: 1/1 -11/23_ 81,473 11/23 — 11/30 _ $923.08 $16,469.88 102,558.28 12/1 -12/31_ 3,692.32 1971_ 48,000.16 17,023.82 65,023.98 1972_ 48,223.24 16,003.16 64,226.40 1973_ 48,000.16 16,900.24 64,900.40 1974_ 58,000.16 21,931.85 79,932.01 It is apparent that in 1970 petition…