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74 documents · 0.22sAllIRCERISAPBGCJoint Board
  1. T.C. Summary Opinion 2010-171 — Willie A. & Charlotte J. Morris v. Commissioner
    IRCCourt RulingsDec 8, 2010related by meaning
    iency on November 24, 2008. Pursuant to section 6503(a) (1), the mailing of the notice of deficiency tolled the limitations period until 60 days after our final decision. Petitioners are required to retain records - 8 - "so long as the contents thereof may become material in the administration of any internal revenue l…
  2. T.C. Memo. 2024-71 — Kenneth Steven Tuma, Sr. & Deborah Ann Tuma v. Commissioner
    IRCCourt RulingsJul 11, 2024related by meaning
    dicated , statutory references are to the Internal Revenue Code , Title 26 U.S.C. (Code), in effect at all relevant times , Rule references are to the Tax Court Rules of Practice and Procedure , and monetary amounts are rounded to the nearest dollar. Served 07/11/24 2 [* 2 ] U.S. Railroad Retirement Board (RRB) in 2015…
  3. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…
  4. T.C. Memo. 2004-258 — Isabel Molina & Isaac Molina, Jr. v. Commissioner
    IRCCourt RulingsNov 10, 2004
    …they believed they were obligated to report this amount after receiving the Form 1099-R. On May 13, 2002, respondent received a Form 656, Offer in Compromise (OIC), from Mr. and Mrs. Molina. Mr. and Mrs. Molina attached a letter dated May 10, 2002 (May 2002 letter), to their OIC. The May 2002 letter explained that the …
  5. T.C. Memo. 2013-10 — Robert A. & Pearl Fletcher v. Commissioner
    IRCCourt RulingsJan 14, 2013
    …54 81,916 12,980 94,896 2000 1,250,983 29,479 10,380 39,859 2001 1,327,452 (27,516) 15,546 (11,970) 2002 1,001,110 297,798 13,949 311,747 20032 -0- 925,640 1,072 926,712 2004 -0- (917,045) -0- (917,045) 2005 -0- (3,943) -0- (3,943) Total 16,356,316 519,577 362,091 881,668 1The Court has derived this column of informati…
  6. T.C. Memo. 2004-287 — Michael J. Barkley v. Commissioner
    IRCCourt RulingsDec 28, 2004
    …96 return on November 23, 1998, his 1997 return on February 4, 2001, and his 1999 return on June 6, 2002. On January 14, 2002, respondent mailed to petitioner a notice of deficiency with respect to petitioner’s 1998 taxable year. In the notice of deficiency, respondent determined that the full amount of the 1998 distri…
  7. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    … however, there was no levy by respondent in this case. Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13, affd. without published opinion 166 F.3d 1201 (2d Cir. 1998), also cited by petitioner, the taxpayer was indicted on charges of violating Federal currency transaction reporting laws. As part of the taxpaye…
  8. T.C. Memo. 2009-100 — Peter I. & Daria A. Basalyk v. Commissioner
    IRCCourt RulingsMay 14, 2009
    …bases of the Memphis and Forest Lakes properties were $92,480 and $53,880, respectively . Tax Years 2002, 2003, and 200 4 During 2002, 2003, and 2004 petitioner Daria A . Basalyk (Mrs . Basalyk) was an employee of the Brecksville-Broadview Heights Board of Education . Petitioner Peter I . Basalyk (Mr . Basalyk) was an …
  9. T.C. Memo. 1997-244 — O. H. Tolley, Jr. & Betty Tolley v. Commissioner
    IRCCourt RulingsMay 29, 1997related by meaning
    … prior years. Easter v. Commissioner , 338 F.2d 968, 969-970 (4th Cir. 1964), affg. per curiam T.C. Memo. 1964-58; Rose v. Commissioner , 55 T.C. 28, 32 (1970). We reject petitioners’ argument that an exception to this rule applies to disputes involving $10,000 or less. To reflect the foregoing, Decision will be entere…
  10. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
    IRCCourt RulingsAug 28, 2008related by meaning
    T .C . Memo . 2008-20 4 UNITED STATES TAX-COUR T WALTER KOWSH, Petitioner v . COMMISSIONER OF . INTERNAL . REVENUE, Responden t Docket No . 15154-06 . Filed August 28, 2008 . Walter Kowsh, pro se . Michelle L . Maniscalco , for respondent . MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N KROUPA, Judge : Respondent determined…
  11. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    ng warned by the Court and after having received notice from the Court in a prior case. 6 On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's position is both frivolous and groundless. Accordingly, we exercise our discretion and award a penalty t…
  12. 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…
  13. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
  14. T.C. Memo. 2008-93 — Blake Sime & Susan M. Atkin v. Commissioner
    IRCCourt RulingsApr 10, 2008
    T .C . Memo . 2008-93 UNITED STATES TAX COUR T BLAKE SIME ATKIN AND SUSAN M . ATKIN, Petitioners v . COMMISSIONER OF INTERNAL REVENUE, Responden t Docket No . 5266-05 . Filed April 10, 2008 . Blake Sime Atkin and Susan M . Atkin, pro sese . Richard W . Kennedy , for respondent . MEMORANDUM FINDINGS OF FACT AND OPINION …
  15. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    v. Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo. 2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v. - 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001). While we acknowledge and are sympathetic to petitioner's financial straits, we have no aut…
  16. T.C. Memo. 2007-90 — Roger F. & Mary A. Duronio v. Commissioner
    IRCCourt RulingsApr 17, 2007
    …ly distribution subject to the 10-percent additional tax. See Lodder-Beckert v. Commissioner , T.C. Memo. 2005-162. Because petitioners have not produced credible evidence that they guaranteed the $19,263 student loan their son obtained in 2002, we do not address the merits of petitioners’ argument that - 5 - the alleg…
  17. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    Parker, Judge: By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows: _Additions to tax_ Sec. Sec. Sec. TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1/31/86 $64,117 $3,206.85 50 percent $16,029.25 of the interest …
  18. PLR 200303058 — Year of Inclusion in Gross Income
    IRCPrivate Letter RulingsJan 17, 2003
    …is directed only to City C and applies only to the amended and restated Plan submitted on April 15, 2002 as revised by the September 9, amendments and to the annuity contract submitted on May 17, 2002, as revised by the amendments submitted on September 9, 2002. Section 6110(k)(3) of the Internal Revenue Code provides …
  19. T.D. 9749 — This regulation addresses the composition of the Joint Board for the Enrollment of Actuaries (the “Joint Board”). The Joint Board establishes standards and qua…
    IRCTreasury DecisionsMar 7, 2016related by meaning
    or (3) must prepare a transfer statement for the transfer of a debt instrument or section 1256 option that is a covered security. T.D. 9751 T.D. 9751 These regulations relate to withholding on foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests. The regulations…
  20. 147 T.C. No. 14 — Pizza Pro Equipment Leasing, Inc. v. Commissioner
    IRCCourt RulingsNov 17, 2016
    zation schedules for plan years 1996 through 2002 and valuation - 9 - results for plan years 2002 through 2006. The plan actuary, an enrolled actuary, also signed Schedules B, Actuarial Information, to the Forms 5500, Annual Return/Report of Employee Benefit Plan, filed by the plan for each of the years at issue. III. …