IRCCourt RulingsOct 3, 1995
…erefore subject to
the deficiency procedures set forth in subch. B of ch. 63 of the
I.R.C. See sec. 6211(a).
Rules 180, 181, and 183.
1
The Court agrees with and adopts the
Opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge
: Respondent determined…
IRCRegulationsDec 19, 2016related by meaning
(a)(1)(iii) (iii) Section 6049(a)(1), relating to information returns with respect to payments of interest aggregating $10 or more in a calendar year, in effect with respect to payments made after December 31, 1962, and the regulations under such section, within the time prescribed for filing such statement (determined…
Notice 2026-31 — This notice sets forth updates on the corporate bond monthly yield curve, the corresponding spot segment rates for April 2026 used under § 417(e)(3)(D), the 24… IRCNoticesJun 1, 2026related by meaning
The Tax Court denied the IRS’s motion to dismiss the case for lack of jurisdiction. In a unanimous opinion, the Tax Court held that section 7508A(d) (as amended in 2019) unambiguously provided for an automatic and mandatory postponement period that incorporated all of the acts referenced by section 7508A(a), from the e…
IRCCourt RulingsJun 10, 2010
…or withholding tax payments ,
is specifically excluded from the computation of a deficiency .
Sec . 6211 (b)(1) . Once a decision is entered the withholding tax
will, however , be treated as a credit against petitioner's
ultimate tax liability , reducing it dollar-for-dollar . See sec .
.31 . The statutory notice inclu…
IRCCourt RulingsMar 14, 2019related by meaning
ho conducted petitioner's CDP hearing, a USPS document relating to the
notice of deficiency for 2012, and a copy of this Court's order and decision in Wesley v. Commissioner, docket No. 6560-14L.
At trial petitioner offered and we admitted into evidence a screen shot of
information he had downloaded from the USPS track…
IRCCourt RulingsAug 16, 2017
…ed
because the understatement of income tax, which equals the deficiency, exceeds
$5,000, see secs. 6211, 6662(d)(2), 6664(a).
The accuracy-related penalty does not apply to any part of an underpayment
of tax if it is shown the taxpayer acted with reasonable cause and in good faith
with respect to that portion. Sec. 66…
86 FR 39910 — Electronic-Filing Requirements for Specified Returns and Other Documents IRCProposed Rules (FR)Proposed Jul 23, 2021related by meaning
(c)(3)(i), and (f) to read as follows:
§ 1.6050I-2
Returns relating to cash in excess of $10,000 received as bail by court clerks.
* * * * *
(c) * * * (1) * * * (i) In general. The information return required by this section must be filed in accordance with the Form 8300 instructions and related publications by the 15t…
IRCCourt RulingsJun 15, 2009
…the tax imposed
.which is shown on the return, reduced by
any rebate (within the meaning of section 6211(b)(2)) .
Section 6015(b)(1) is similar to former sectio n
6013(e)(1) .20 We may look at cases interpreting sectio n
6013(e)(1) for guidance when analyzing parallel provisions of
I
section 6015 . See Jonson v . Co mm…
IRCCourt RulingsOct 19, 2010related by meaning
ions, this Court concludes that a
section 6673 penalty of $500 is appropriate. It is
"inappropriate that taxpayers who promptly pay their taxes should have the cost of Government and tax collection improperly
increased by citizens apparently unwilling to obey the law or
shoulder their assigned share of the Government c…
IRCCourt RulingsNov 7, 1996
… and is subject to the
deficiency procedures set forth in subch. B of ch. 63 of the
I.R.C. See sec. 6211(a).
Rules 180, 181, and 183.
1
The Court agrees with and adopts the
Opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge
: Respondent determined…
IRCCourt RulingsJun 11, 1996
… and is subject to the
deficiency procedures set forth in subch. B of ch. 63 of the
I.R.C. See sec. 6211(a).
4
Respondent concedes that petitioner Joan K. Powell is not
liable for the deficiency in issue herein.
Rules 180, 181, and 183.
1
The Court agrees with and adopts the
Opinion of the Special Trial Judge, which is…
IRCCourt RulingsAug 13, 1990related by meaning
t C. Slaton purports to extend the period of limitations for 1983 only.
Title 29 U.S.C. sec. 1203(a) (1982) contains a similar requirement. It states: Unless the Secretary of the Treasury finds that the collection of a tax is in jeopardy, in carrying out the provisions of section 4975 of Title 26 (relating to tax on pr…
IRCCourt RulingsApr 30, 2003
…deficiency may not
properly be assessed until our decision in this case has become
final. See secs. 6211(a), 6212(a), and 6213(a).
- 7 -
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155
.
67 T.C. 29 — Federal Land Bank Asso. v. Commissioner IRCCourt RulingsOct 6, 1976related by meaning
or lack of jurisdiction.
Appropriate orders will be issued.
Statutory references are to the Internal Revenue Code of 1954, unless otherwise indicated. Sec. 7476 is a new provision of the Internal Revenue Code. It provides taxpayers with a forum in which they may receive determinations of whether their plans are qualifi…
IRCCourt RulingsJun 11, 1996
… and is subject to the
deficiency procedures set forth in subch. B of ch. 63 of the
I.R.C. See sec. 6211(a).
3
Respondent concedes that petitioner Harold E. Emmons is
not liable for the deficiency in issue herein. See also infra
note 6.
Opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIA…
IRCCourt RulingsMay 6, 2014related by meaning
on 6301 empowers the Commissioner to collect the taxes imposed by
the internal revenue laws. To further that objective, Congress has provided that the Commissioner may effect the collection of taxes by, among other methods, liens
and levies. Section 6321 imposes a lien in favor of the United States on all
property and …
IRCCourt RulingsJun 12, 1996
…t of tax imposed which is shown on the return,
reduced by any rebate (within the meaning of section 6211(b)(2)).
Sec. 6662(d)(2)(A).
The accuracy-related penalty under section 6662(b)(2) does
not apply with respect to any portion of an underpayment if it is
shown that there was reasonable cause for such portion and tha…
IRCCourt RulingsSep 24, 2007related by meaning
trates actual knowledge by
petitioner of the . IRA distribution, at the time she signed th e
6 The five criteria of sec . 6015(b)(1) are conjunctive . Having concluded that sec . 6015(b)(1)(C) is not satisfied, we
need not, and do not, discuss the criteria of the other
subsections of sec . 6015(b)(1) .
- 11 -
return . …
85 FR 27693 — Effect of Section 67(g) on Trusts and Estates IRCProposed Rules (FR)Proposed May 11, 2020related by meaning
ies). Other personnel from the Treasury Department and the IRS, however, participated in their development.
Statement of Availability of IRS Documents The IRS notice cited in this document is published in the Internal Revenue Bulletin and available from the Superintendent of Documents, U.S. Government Publishing Office…