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64 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2004-287 — Michael J. Barkley v. Commissioner
    IRCCourt RulingsDec 28, 2004
    ble for additions to tax under secs. 6651(a)(2) and 6654; (2) petitioner is entitled to deduct expenses relating to his apartment rental activity; (3) petitioner’s 1998 filing status is married filing jointly; and (4) petitioner’s payment of $2,000, made on or about Mar. 7, 2001, was incorrectly credited as $340, and r…
  2. T.C. Memo. 2024-67 — Fabricio Moran v. Commissioner
    IRCCourt RulingsJun 17, 2024
    …ursuant to section 6020(b) is treated as the “return” filed by the taxpayer for this purpose. See § 6651(g). On September 12, 2022, the IRS prepared an SFR setting forth the adjustments discussed above. Respondent has included with his Motion a properly executed Certification establishing that the SFR satisfied the req…
  3. T.C. Memo. 2022-29 — Shawn Stephen Salter v. Commissioner
    IRCCourt RulingsApr 5, 2022
    …ly if “it is shown that such failure is due to reasonable cause and not due to willful neglect .” § 6651(a)(1). The taxpayer bears the burden of proof on this point . Higbee v. Commissioner, 116 T.C. 438, 447 (2001). Petitioner did not allege or prove that he had reasonable cause for failure to file a return for 2013. …
  4. T.C. Memo. 2000-391 — Robert C. Geib v. Commissioner
    IRCCourt RulingsDec 28, 2000related by meaning
    … thereof, in the taxable period. See sec. 6011; sec. 54.6011-1(b), Pension Excise Tax Regs. Section 6651(a)(1) imposes an addition to tax for failure to file a required return, unless petitioner establishes that such failure is due to reasonable cause and not willful neglect. Petitioner failed to file excise tax return…
  5. T.C. Memo. 2014-14 — Ries Enterprises, Inc. v. Commissioner
    IRCCourt RulingsJan 27, 2014
    …ains delinquent, up to a maximum addition of 25% for returns more than four months delinquent. Sec. 6651(a)(1). The addition to tax for delinquent payment is calculated as 0.5% of the amount shown as tax on -15- [*15] the return but not paid, with an additional 0.5% for each month or fraction thereof during which the f…
  6. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999
    … imposed by section 4975(a). 5 D. Whether Petitioners Are Liable for Additions to Tax Under Section 6651(a)(1) Disqualified persons liable for the tax under section 4975(a) must file an annual return on Form 5330 for each prohibited transaction. Sec. 6011; sec. 54.6011-1(b), Pension Excise Tax Regs. Neither petitioner …
  7. 101 T.C. 518; 101 T.C. No. 34 — Janpol v. Commissioner
    IRCCourt RulingsDec 7, 1993
    … Inc. (ajvw), as follows: Docket No. 5586-92 Transferee liability Deficiency Year See. 4975(a) Sec. 6651(a)(1) Sec. 4975(a) Sec. 4975(b) Sec. 6651(a)(1) 1986 $781 $195 $15,958 - - - $3,990 1987 41,259 - - - 10,315 1988 91,416 - - - 22,854 1991 $2,747,607 Docket No. 5587-92 Transferee liability Deficiency Year Sec. 4975…
  8. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    …d for purposes of - 50 - determining the addition to tax for failure to file a return under section 6651(a)(1). Sec. 6651(g)(1). However, returns prepared by the Secretary are treated as if they were filed by the taxpayer for purposes of determining the amount of the addition under section 6651(a)(2) for failure to pay…
  9. 77 T.C. 1197; 2 Employee Benefits Cas. (BNA) 2188 — Shut Out Dee-Fence, Inc. v. Commissioner
    IRCCourt RulingsDec 2, 1981related by meaning
    n the deficiency actions and, thus, we must follow the legislature’s mandate and dismiss this case. An appropriate order of dismissal will be entered. ^ince this is a preliminary jurisdictional motion, the Court has concluded that the post-trial procedures of Rule 182, Tax Court Rules of Practice and Procedure, are not…
  10. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997
    …oth & Debra Booth (J&D Booth), docket No. 2546-94 Addition to Tax Penalty Sec. Sec. Year Deficiency 6651(a)(1) 6662(a) 1990 $17,820 --- $3,564 1991 10,263 --- 2,053 Young & Young, Ltd.(Young & Young), docket No. 5754-94 Addition to Tax Penalty Sec. Sec. Year Deficiency 6651(a)(1) 6662(a) 1989 $12,744 $637 $2,549 Howard…
  11. T.C. Memo. 2012-168 — Steven W. & Gayle F. Repetto v. Commissioner
    IRCCourt RulingsJun 14, 2012related by meaning
    …Penalties A. s Burden of Proof Respondent bears the burden of production with regard to the section 6651(a)(1) and (2) additions to tax and the section 6662A penalties. See sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). To meet his burden, respondent must produce sufficient evidenòe that it is appr…
  12. T.C. Memo. 2018-138 — Larry W. Macdonald v. Commissioner
    IRCCourt RulingsAug 27, 2018related by meaning
    0 and $5,379, respectively; and (4) liable for an accuracy-related penalty under section 6662(a) for 2013 and 2014 of $3,267 and $7,364, respectively. The examining agent's immediate supervisor approved the section 6662(a) penalties in writing by making an entry in the Correspondence Examination Automation Case Support…
  13. 87 FR 14722 — Procedures Governing the Filing and Processing of Prohibited Transaction Exemption Applications
    ERISAProposed Rules (FR)Proposed Mar 15, 2022related by meaning
    cy or attempt to commit any such crimes or a crime of which any of the foregoing crimes is an element; or any crime described in ERISA section 411; or (B) Convicted by a foreign court of competent jurisdiction or released from imprisonment, whichever is later, as a result of any crime, however denominated by the laws o…
  14. T.C. Memo. 2007-68 — Christina L. Belmont v. Commissioner
    IRCCourt RulingsMar 22, 2007related by meaning
    a “required annual payment” for that year. Sec. 6654(d). A “required annual payment” is equal to the lesser of (1) 90 percent of the tax shown on the individual’s return for that year (or, if no return is filed, 90 percent of his or her tax for such year), or (2) if the - 7 - individual filed a return for the immediat…
  15. T.C. Memo. 2008-201 — Joseph R. Banister v. Commissioner
    IRCCourt RulingsAug 27, 2008
    …income that he received in 2002 . R determined a deficiency and additions to tax pursuant to secs . 6651(a)(1) and (2) and 6654(a), I .R .C . Held : P is liable for the deficiency and the addition to tax pursuant to sec . 6651(a)(1), I .R .C . P is not liable for the additions to tax pursuant to secs . 6651(a)(2) and 6…
  16. T.C. Memo. 2015-47 — Balvin Anthony McKnight v. Commissioner
    IRCCourt RulingsMar 16, 2015related by meaning
    on 6662 imposes a 20% accuracy-related penalty on any underpayment attributable to any substantial understatement of income tax. Sec. 6662(a), (b)(2). An understatement is "substantial" if it exceeds the greater of $5,000 or 10% of 5Petitioner's Wells Fargo statement for the period ending September 12, 2011, shows a ch…
  17. T.C. Memo. 1998-388 — Robert B. Keenan v. Commissioner
    IRCCourt RulingsNov 2, 1998
    …is issue. Issue 7. Additions to Tax The last issue is whether petitioner is liable for the sections 6651( a) and 6654(a) additions to tax determined by respondent. Respondent contends that petitioner is liable for these additions for the years in issue; petitioner, on the other hand, disagrees. Section 6651(a)(1) impos…
  18. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020
    …Benton is eligible for an exception to the additional tax prescribed in section 72(t). III. Section 6651(a)(1) Section 6651(a)(1) imposes an addition to tax for failure to timely file a tax return unless it is shown that such failure is due to reasonable cause and not due to willful neglect. The addition to tax is equa…
  19. 74 T.C. 651 — Judd v. Commissioner
    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…
  20. T.C. Memo. 1996-545 — Creston Swaim v. Commissioner
    IRCCourt RulingsDec 17, 1996
    ayer shows that the delay was due to reasonable cause and not willful neglect. Sec. 6651(a)(1). Petitioner's 1992 Federal income tax return was due on April 15, 1993. Sec. 6072(a). Respondent received petitioner's Form 1040NR (which is dated June 15, 1993) on June 22, 1993. However, petitioner introduced no evidence or…