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85 documents · 0.28sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2020-151 — Scott Lashua v. Commissioner
    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…
  2. T.C. Memo. 2014-229 — Grace Foundation, R. S. Ohendalski, Trustee v. Commissioner
    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)…
  3. U.S. Tax Court — Cynthia M. Martinez v. Commissioner
    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…
  4. T.C. Memo. 2003-12 — Richard J. Meyer, III v. Commissioner
    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…
  5. T.C. Summary Opinion 2011-138 — Allan K. Vetere v. Commissioner
    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…
  6. T.C. Memo. 2013-84 — K & K Veterinary Supply, Inc. v. Commissioner
    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 …
  7. T.C. Memo. 2009-140 — James A. Haigh v. Commissioner
    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(…
  8. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    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…
  9. 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). …
  10. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    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…
  11. T.C. Memo. 2007-327 — Gregory Eugene Thompson v. Commissioner
    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…
  12. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    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…
  13. PLR 200118016 — Notification of Secretary of Labor
    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…
  14. T.C. Memo. 2002-273 — Augustin B. Jombo v. Commissioner
    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…
  15. T.C. Memo. 1997-507 — Sam E. Scott v. Commissioner
    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 …
  16. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    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…
  17. T.C. Memo. 2024-6 — Clair R. Couturier, Jr. v. Commissioner
    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…
  18. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    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…
  19. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    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…
  20. U.S. Tax Court — John C. Armbrust v. Commissioner
    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…