IRCCourt RulingsMar 31, 2015
…t Officer Degiovanni
determined that petitioners' RCP was $16,310 and their monthly net income was $171. She therefore rejected petitioners' proposed OIC of $950. She offered
petitioners the choice of either increasing their OIC or accepting an installment
agreement with a payment of $171 per month and the filing of a …
IRCCourt RulingsMay 28, 2003related by meaning
r the Northern District of
Illinois, in which petitioner pleaded guilty to one count of
obstructing and impeding the due administration of the Code in violation of section 7212(a).
3
- 6 -
3
(...continued)
corruptly or by force or threats of force (including
any threatening letter or communication) endeavors to
intimid…
ERISARegulationsJan 1, 2017related by meaning
[Reserved]
88 FR 88494 — Federal Independent Dispute Resolution (IDR) Process Administrative Fee and Certified IDR Entity Fee Ranges IRCFinal Rules (FR)Dec 21, 2023
icy.
https://www.brookings.edu/blog/usc-brookings-schaeffer-on-health-policy/2021/03/16/recommendations-for-implementing-the-no-surprises-act/. Back to Citation
168.
United States Census Bureau (March 2020).
2017 SUSB Annual Data Tables by Establishment Industry, Data by Enterprise Receipt Size. https://www.cen…
IRCCourt RulingsJul 8, 1980related by meaning
minations should also be within our jurisdiction. Regardless of the logic of petitioners’ position, we are constrained to deny their motion to vacate. The United States Tax Court has limited jurisdiction. See sec. 7442. Under this jurisdictional umbrella fall generally income, estate, gift, and miscellaneous excise tax…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
e taxes
Pensions
Reporting and recordkeeping requirements
26 CFR Part 301
Employment taxes
Estate taxes
Excise taxes
Gift taxes
Income taxes
Penalties Reporting and recordkeeping requirements
Proposed Amendments to the Regulations
Accordingly, 26 CFR parts 1, 53, 54 and 301 are proposed to be amended as follows:
PART 1…
IRCCourt RulingsMar 3, 2016related by meaning
, petitioner tried to keep his tax records and IRS paperwork
for 10 years.
In 2001 petitioner ran a small pharmacy in addition to working at a Federal Government hospital. On April 19, 2001, he was charged, along with two other
codefendants, with diversion of pharmaceuticals from the Department of Veterans
Affairs, and…
IRCCourt RulingsMar 22, 2007related by meaning
ddition to tax must be
sustained.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever the taxpayer’s position is frivolous or
groundless or the taxpayer has instituted or pursued the
proceeding primarily for delay. Respondent has n…
IRCCourt RulingsSep 15, 2005related by meaning
Court, the two cases were
consolidated for hearing on the motions to dismiss. The hearing
was held on November 29, 2004, in San Francisco, California. Discussion
Section 6033(a)(1) requires an organization exempt from
taxation under section 501(a) to file."an annual return, stating
specifically the ite s of gross incom…
IRCCourt RulingsSep 26, 2001
…683 F.2d 57, 58 (3d Cir. 1982), affg. T.C. Memo. 1980-532; Eanes
v. Commissioner
, 85 T.C. 168, 170-171 (1985).
While the result to petitioner appears harsh, we cannot
ignore the flush language of the statute and, in effect, rewrite
the statute to achieve what seems to be a more equitable result.
See Eanes v. Commissio…
83 FR 36417 — Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions IRCFinal Rules (FR)Jul 30, 2018related by meaning
ted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business, and no comments were received. Drafting Information
The principal author of these regulations is Charles Gorham of the Office of Associate Chief Counsel (Income Tax and Accounting). Other personnel fr…
IRCCourt RulingsJul 24, 2013
T C. Memo. 2013-171
UNITED STATES TAX COURT
li
SEAN RICHARDS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 844-12. Filed July 24, 2013.
Sean Richards, for himself.
Michael R. Fiore, for respondent.
MEMORANDUM OPINION
GUSTAFSON, Judge: The Internal Revenue Service (IRS) determined a
deficiency o…
89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities IRCFinal Rules (FR)Apr 25, 2024related by meaning
not impose substantial direct compliance costs on State and local governments, and do not preempt State law within the meaning of the Executive order. Statement of Availability of IRS Documents
IRS Revenue Procedures, Revenue Rulings, Notices, and other guidance cited in this document are published in the Internal Reve…
IRCCourt RulingsDec 8, 2010
T.C. Summary Opinion 2010-171
UNITED STATES TAX COURT
WILLIE A. AND CHARLOTTE J. MORRIS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent '
Docket No. 4441-09S. Filed December 8, 2010.
Willie A. and Charlotte J. Morris, pro se.
Edwin B. Cleverdon, for respondent.
THORNTON, Judge: This case was heard pursuant…
IRCCourt RulingsMay 19, 2011related by meaning
ion 6662(a) and (b) (2).
Generally, section 6662(a) and (b) (1) authorizes the
Commissioner to impose a 20-percent penalty on the portion of an
- 72 - underpayment of income tax attributable to negligence or
disregard of rules or regulations. The term "negligence"
includes any failure to make.a reasonable attempt to co…
IRCCourt RulingsJul 15, 1997
… Sec.
Year
Deficiency
6651(a)(1)
6653(a)(1)(A)
6653(a)(1)(B)
6661(a)
1987 $76,684 19,360 4,213
1
19,171
1
50 percent of the interest due on the deficiency.
Douglas R. Prince, D.D.S., M.S., P.C., docket No. 8457-94
Additions to Tax
Taxable Secs. Secs.
Year Ending Sec. 6653(a)(1)/ 6653(a)(2)/ Sec.
June 30
Deficiency
6651…
IRCCourt RulingsJul 12, 2005
T.C. Memo. 2005-171
UNITED STATES TAX COURT
SYLVIA A. DUNCAN, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 329-04. Filed July 12, 2005.
Sylvia A. Duncan, pro se.
Daniel N. Price
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge
: Respondent determined a deficiency of $2,25…
87 FR 80097 — Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled Qualified Investment Entities IRCProposed Rules (FR)Proposed Dec 29, 2022related by meaning
). However, other personnel from the Treasury Department and the IRS participated in their development.
List of Subjects in 26 CFR Part 1
Income taxes Reporting and recordkeeping requirements
Proposed Amendments to the Regulations
Accordingly, the Treasury Department and the IRS propose to amend 26 CFR part 1 as follow…
IRCCourt RulingsJul 19, 2002
T.C. Memo. 2002-171
UNITED STATES TAX COURT
J. KELLY ANDERSON AND MARTHA L. ANDERSON, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10760-00. Filed July 19, 2002.
Joe K. Gordon
, for petitioners.
Denise G. Dengler
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge
: Petition…
ERISARegulationsApr 8, 2024related by meaning
(f)(11)(i)(E) (E) Any felony or conspiracy involving the larceny, theft, robbery, extortion, forgery, counterfeiting, fraudulent concealment, embezzlement, fraudulent conversion, or misappropriation of funds or securities; or
(f)(11)(ii) (ii) A statement describing the applicable investigation, examination, litigation,…