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…
Notice 2004-78 — Actuarial assumptions; distributions under section 101 of Pension Funding Equity Act of 2004. This notice provides guidance in question and answer format on th… IRCNoticesNov 29, 2004
he plan year beginning in 2004 to an equivalent straight life annuity using 5.5% rather than the applicable interest rate of 5.25% as under prior law. In such a case, to satisfy the limitations of § 415 of the Code, the maximum single-sum distribution for a participant who is age 65 in 2004 would be $1,866,645 calculat…
IRCCourt RulingsFeb 10, 2009related by meaning
ic v . ,Commissioner , T .C . Memo . 1992--
609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . .
In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her
medical condition
. She explained at trial that although she
received treatment from doctors in 2005, she did …
IRCCourt RulingsJan 16, 2002related by meaning
…nial of
equitable relief under the last sentence of section 66(c). Beck
- 9 -
v. Commissioner, T.C. Memo 2001-198. Here, we review
respondent's denial of equitable relief under section 66(c) for
abuse of discretion. Id ; see also Fernandez v. Commissioner,
114 T.C. 324 (2000), Butler v. Commissioner, 114 T.C. 276 (2000…
IRCCourt RulingsFeb 25, 2016
on of the deficiencies,
penalties, and additions to tax for 2004 and 2005.
In his answering brief respondent concedes that petitioner is entitled to a deduction for an additional $15,800 in travel expenses previously disallowed for
2004. Respondent also concedes that petitioner is not liable for an enhanced
accuracy-re…
IRCCourt RulingsJan 14, 2013
lated penalty with respect to
all of its concessions listed in this paragraph.
[*4] for the 2003, 2004, and 2005 tax years, including the pension plan contributions paid on behalf of Robert A. and Pearl Fletcher for the 2003 and 2004
tax years,
(2) whether the compensation TORCH paid to the Fletchers' daughter,
Grace-A…
IRCCourt RulingsAug 31, 2021related by meaning
including granting CNC status - - s ince petitioner did not furnish necessary
documentation. On the basis of these circumstances M s. Rego performed a balancing test, concluding that the proposed levy did balance the needs of
collection with the concerns of petitioner. On the basis of our review w e hold that
M s. Rego…
IRCCourt RulingsDec 18, 2012
…clude dismissal of this case and entry of * * * decision[s] against petitioner[s]."
On December 20, 2004, respondent filed motions to impose sanctions on the
grounds that petitioners had failed to comply with the Court's November 10, 2004,
- 28 -
[*28] orders, in that petitioners had not made available to respondent's …
IRCCourt RulingsJun 18, 1997related by meaning
… years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
T.C. Memo. 1997-277
UNITED STATES TAX COURT
MARGARET M. MERKER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26855-95. Filed June 18, 1997.
Margaret M. Merker, pro se.
Marjory A. Gilbert
, for respon…
IRCCourt RulingsSep 23, 2019related by meaning
timony relating to the attempted sale of the property was vague, murky, and
unaccompanied by any related documentary evidence. The complete absence of relevant documents undermines his credibility. Therefore, we find that the
-10Canadian property was not held for sale from October 2006 to October 2007 and
was placed in…
IRCRegulationsSep 9, 2016
… using the fair market value of stock as of the date on the option is granted. During calendar year 2004, the aggregate fair market value of stock with respect to which E's options are exercisable for the first time exceeds $100,000. Therefore, the option for Y Corporation stock is treated as an incentive stock option,…
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 RulingsMar 9, 2011related by meaning
16determination to proceed with the-proposed levy as a permissible
exercise of discretion.
We have considered all' arguments raised by the parties and have found those arguments not discussed here-in to be irrelevant
or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
IRCCourt RulingsJun 6, 2019related by meaning
DRC
T.C. Memo. 2019-67
UNITED STATES TAX COURT
MARIA SHENORAH MCCREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10129-14L. Filed June 6, 2019.
Maria Shenorah McCree, pro se.
Moenika N. Coleman, Linda L. Wong, Michael S. Navarro, and Cindy L.
Wofford, for respondent.
MEMORANDUM FINDINGS OF FA…
IRCCourt RulingsNov 1, 2005related by meaning
…d all Rule references
are to the Tax Court Rules of Practice and Procedure. All
(continued...)
T.C. Memo. 2005-258
UNITED STATES TAX COURT
JOYCE M. THOMAS, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10824-03. Filed November 1, 2005.
Joyce M. Thomas, pro se.
Andrew R. Moore
, for respondent.
…
IRCCourt RulingsJun 25, 2013related by meaning
T.C. Summary Opinion 2013-51
UNITED STATES TAX COURT
MARTIN TOOMBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27665-10S. Filed June 25, 2013.
James O. Creech III, for petitioner.
Thomas D. Yang, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
p…
Rev. Proc. 2004-15 — Minimum funding standards; waivers; notice. This procedure sets forth guidelines for requesting waivers of the minimum funding standards with respect to define… IRCRevenue ProceduresFeb 17, 2004
…nces, preliminary conferences may be afforded in addition to conferences available under Rev. Proc. 2004-4, 2004-1 I.R.B. 125.
SECTION 6. BANKRUPTCY PETITIONS
If the applicant or a significant number of controlled group members file a bankruptcy petition after the request for a waiver of the minimum funding standard is…
IRCCourt RulingsJun 21, 2011related by meaning
efore the loan was not a
taxable distribution in 2003. On March 21, 2006, the Air Force
removed petitioner from service and 'notified the TSP. The Air Force did not reinstate petitioner within 31 days from March 21,
2006. As a result, the TSP notified petitioner that the loan
provisions required repayment of the outsta…
IRCCourt RulingsSep 13, 2010
Memo . 1997-331 ; Speer v .
Commissioner
Memo . 1993- 5
The fol
accuracy of
appears exce
amount of ti
(2) the Geor
during 2004 .
Further
petitioner c T .C . Memo . 1996-323 ; Goshorn v . Commissioner , T .C .
1 8 .
owing factors further diminish the credibility and
etitioner's claim : (1) The number of hours claimed
~…
IRCCourt RulingsSep 24, 2007related by meaning
moot, or irrelevant .
To reflect the foregoing,
Decision will be entere d
for respondent .
8Sec . 6654(e) provides two exceptions to the sec . 6654(a) addition to tax . First, the addition is not applicable if the
tax shown on the taxpayer's return for the year in question (or,
if no return is filed, the taxpayer's tax…