IRCCourt RulingsNov 9, 2020
SR
T.C. Memo. 2020-151
UNITED STATES TAX COURT
SCOTT LASHUA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9144-19. Filed November 9, 2020.
Scott Lashua, pro se.
Brian M. Howell, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: Respondent determined a deficiency of $2,964 in
petitioner's Federa…
IRCCourt RulingsNov 6, 2014related by meaning
ski's March 19, 2012, letter correctly refers to section 6652 (and not
section 6552) and clearly indicates his understanding that section 6652 was the statutory provision at issue. See, e.g., Buckardt v. Commissioner, T.C. Memo.
2012-170, aff'd, ___Fed. Appx. ___, 114 A.F.T.R.2d (RIA) 2014-5745 (9th Cir.
Aug. 20, 2014)…
IRCCourt RulingsDec 29, 2008
…reason to know that the liability would not be
paid'" . Washington v . Commissioner , 120 T .C . at 151 .
4 . Legal Obligatio n
This factor comes into effect only when "the nonrequesting
spouse has a legal obligation to pay the outstanding income tax
liability pursuant to a divorce decree or agreement ." Rev . Proc .
2…
IRCCourt RulingsJan 13, 2003
… under the age of 13 and with respect to whom the taxpayer is
entitled to a deduction under section 151(c).
4
Sec. 21(b)(1)(A).
Mr. Meyer is not entitled to a deduction for Richard under
- 9 -
section 151(c) for 1994, 1995, or 1996. Accordingly, Richard is
not a qualifying individual. Therefore, we conclude that Mr.
Me…
IRCCourt RulingsDec 19, 2011related by meaning
T.C. Summary Opinion 2011-138
UNITED STATES TAX COURT
ALLAN K. VETERE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18287-10S. Filed December 19, 2011.
Allan K. Vetere, pro se.
Kimberly A. Kazda and Bryce Nakamura (student) , for
re spondent .
GERBER, Judge : This case was' hÉaÊd pursuant to th…
IRCCourt RulingsMar 25, 2013
… (5th Cir. 1987), aff'g T.C. Memo. 1985-267;
Charles Schneider & Co. v. Commissioner, 500 F.2d 148, 151 (8th Cir. 1974),
aff'a T.C. Memo. 1973-130. Courts have considered various factors in assessing
the reasonableness of compensation, such as: employee qualifications; the nature,
- 10 -
[*10] extent, and scope of the …
IRCCourt RulingsJun 15, 2009related by meaning
(including interest, penalties,
and other amounts) for such taxable year to the
extent such liability is attributable to suc
h
understatement .
- 2 8 Section 6015(b)(3) provides : "For purposes of this subsec
tion, the term `understatement' has the meaning given to such
term by section 6662(d) (2) (A) ." Section 6662(…
IRCCourt RulingsDec 11, 2003
…ect petitioner’s claim, raised at trial, to Schedule E losses.
V. The Dependency Exemptions
Section 151(a) and (c)(1) allows deductions for exemptions
for dependents. In order to be entitled to dependency exemptions
for three of his children, petitioner must show that each child
meets the statutory definition of “depen…
T.D. 9836 — These final regulations provide guidance regarding substantiation and reporting requirements for cash and noncash charitable contributions. The final regulatio… IRCTreasury DecisionsAug 13, 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 authors of these regulations are Charles Gorham and Karin Gross of the Office of Associate Chief Counsel (Income Tax and Accounting). …
IRCCourt RulingsFeb 9, 2023
…y effective for tax years beginning after April 21, 1993. Id. sec.
- 1T(h) (1994) (effective date).
151
Second, it redesignated the 1968
regulations (including subsequent amendments) and made them
effective for tax years beginning on or before April 21, 1993. 26 C.F.R.
se cs. 1.482- 1A and-2A (1994); T.D. 8470, para. 1…
IRCCourt RulingsOct 31, 2007related by meaning
ner's legal
obligations here . See, e .g ., Pessin v . Commissioner , 59 T .C .
473, 489 (1972) ; Rosanova v . Commissioner , T .C . Memo . 1985-306 ; Grant v . Commissioner , T .C . Memo . 1980-242 .
-11IV . Section 6673 Penalt y
We now consider whether petitioner should be held liable for
a penalty under section 6673…
IRCCourt RulingsFeb 12, 2014
…A.
- 17 -
"notified" in the section involved in that case, see Stovall v. Commissioner, 101
T.C. at 151, the Secretary had promulgated respective regulations under section
1033(a), relating to the deferral of gain on an involuntary conversion, and section
1034(j)(1),9 relating to the deferral of gain on the sale of a p…
IRCPrivate Letter RulingsMay 4, 2001related by meaning
OFFICE OF
CHIEF COUNSEL
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
January 31, 2001
Number: 200118016
Release Date: 5/4/2001
WTA-D-126830-00/CC:TEGE:EB:QP1
UILC: 4975.07-00
INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE
MEMORANDUM FOR Area Counsel (TE/GE), Pacific Coast/Ce…
IRCCourt RulingsOct 29, 2002related by meaning
es on private income having its
source in the receiving State and capital taxes on
investments made in commercial undertakings in the
receiving State; Similarly, article 49(d) of the Vienna Convention on Consular
Relations (article 49), 21 U.S.T. at 108, provides that consular
officers and employees are exempt from all…
IRCCourt RulingsNov 12, 1997related by meaning
iling extensions
constituted his sole defense to the section 6651 (a)(1) addition to
tax, petitioner has not shown that his failure to timely file his 1991 tax return was due to reasonable cause and not willful
neglect. See C rocker v. Commissioner
, supra
at 913. Accordingly,
we hold that petitioner is liable for the …
IRCCourt RulingsOct 9, 1997
…s paid for PRMB's. Accordingly, the increase in the required reserve at the
1988 plan yearend is $9,151,405 ($13,243,405 less $4,092,000).
Consequently, the total reserve balance should be $33,405,883 at
the 1988 yearend ($24,254,478 plus $9,151,405). The November 30,
1988, yearend balance of the VEBA Trust, however, w…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
IRCCourt RulingsApr 2, 2020
…ice of Appeals did not document the findings or
detenmination of the audit reconsideration group.
- 151 -
[*151] action". The lien-filing notice stated the "Amount on Lien" for the 2004
tax year was $17,071.22. It also stated that the date of assessment was August 1,
2011, in the amount due for the 2004 tax year. The l…
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 RulingsJan 19, 2010related by meaning
JOHN C . . A MBRUST, Petitioner v .
COMMISSTONEROF INTERNAL 'REVENUE, Responden t
.° Filed .' January` "19, 2010 .
GOLDBERG , Specia l Trial" Judge : ,' This case w as heard-pursuant
to the provision ` s of secti n6 7463 of' .the Internal Revenue Code i n
effect at the time the {pet'tion was filed . Pursuant ' to '-sec…