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61. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    ccuracy-related penalty under section 6662. OPINION I. Preliminary Matters Petitioner argues that respondent bears the burden of proof with respect to his unreported income for both tax years. For the reasons below, we disagree. Generally, the Commissioner's determinations in a notice of deficiency are presumed correct…
62. 82 T.C. 843; 82 T.C. No. 65 — Green v. Commissioner
    IRCCourt RulingsMay 30, 1984related by meaning
    ents of section 2039(c)(3). Due to concessions and in order to reflect petitioner’s claim for an overpayment, Decision will be entered under Rule 155. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1954 as amended and in effect at the date of death, and all references to Rules ar…
63. 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…
64. 86 FR 55756 — Requirements Related to Surprise Billing; Part II
    IRCProposed Rules (FR)Proposed Oct 7, 2021related by meaning
    ted page 55757) in this document. The preamble to the temporary regulations contains the agency's rationale and provides a regulatory impact analysis. Drafting Information The principal author of this notice of proposed rulemaking is Kari DiCecco, Office of Associate Chief Counsel (Employee Benefits, Exempt Organizatio…