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…
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…
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…
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 …
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…
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…
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…
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 …
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…
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…
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…
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…
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…
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
…
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…
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…
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 …
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 …
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…
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. …