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61. T.C. Memo. 2014-227 — Brian K. Brinkley v. Commissioner
    IRCCourt RulingsOct 30, 2014related by meaning
    nsation. He then used his 2011 income tax return in an attempt to "regain" his desired preferential tax treatment that he had earlier abandoned by not challenging Zave. We cannot presume that in an agreement to pay petitioner for completing two requirements Zave actually intended for the entire amount to be paid with r…
62. T.C. Memo. 2025-60 — Albert Mark Fonda v. Commissioner
    IRCCourt RulingsJun 23, 2025related by meaning
    one fluent in English knows that the word ‘includes’ cannot be assumed to mean ‘includes only .’ . . .”) ; Waltne r , 107 T.C.M. (CCH) at 1201 (citing United States v. Lat ham , 754 F.2d 747, 750 (7th Cir. 1985) ) . In sum, petitioner’s arguments have been rejected by the courts in hundreds of cases, and we will not di…
63. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    n 6662(a) and (b)(1) and (2), a taxpayer may be liable for a penalty of20% 5 Over petitioner's objection respondent introduced a literal transcript of account for petitioner's 2010 tax year. The literal transcript contains no reference to any SFRs. Even if it did, the literal transcript does not establish that the requ…
64. 142 T.C. No. 4 — Law Office of John H. Eggertsen P.C. v. Commissioner
    IRCCourt RulingsFeb 12, 2014related by meaning
    ust decide (1) whether section 4979A(a) imposes an excise tax on petitioner for its taxable year 2005 and (2) if so, whether the period of limitations under section 4979A(e)(2)(D) has expired for assessing that tax for that year. We turn first to whether section 4979A(a) imposes an excise tax on petitioner for its taxa…
65. T.C. Memo. 2022-100 — Donald Furrer & Rita Furrer v. Commissioner
    IRCCourt RulingsSep 28, 2022
    … See § 1015(a). CRAT I and CRAT II sold the corn and soybeans transferred to them for $469,003 and $691,827 , respectively. Because each CRAT had a basis of zero in the crops, they realized profit s of $469,00 3 and $691,827, respectively, on those sales. See § 1001. The corn and soybeans were ordinary income property …
66. 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…
67. T.C. Memo. 2015-162 — Charles Dereck Adams & Melinda Elizabeth Adams v. Commissioner
    IRCCourt RulingsAug 17, 2015
    …ailing to argue). [*3] 59-1/2 or older when he made these withdrawals. The withdrawals totaled $224,691, as follows: Source Amount Thrift Savings Plan $150,000 Thrift Savings Plan 22,720 Charles Schwab IRA 51,971 Total retirement income 224,691 Petitioners received an extension of time to file their 2010 Federal income…
68. 110 T.C. No. 11 — Albert Lemishow v. Commissioner
    IRCCourt RulingsFeb 18, 1998related by meaning
    statutory provisions and the legislative histories of those provisions, we hold that petitioner's use of the distributions from his Keogh and IRA's to purchase stock which he then contributed to the Smith Barney IRA does not constitute a tax-free rollover contribution under section 402(c) or 408(d)(3), respectively. 3 …
69. T.C. Summary Opinion 2003-83 — Manuel Francisco Palomo & Jane Lyon Potter v. Commissioner
    IRCCourt RulingsJun 24, 2003related by meaning
    a section 6662 accuracyrelated penalty is due with respect to petitioners' tax return for 1999. Section 6662(a) imposes a penalty of 20 percent of the portion of the underpayment attributable to negligence or disregard of rules or regulations. See sec. 6662(a) and (b)(1). Negligence is defined as any failure to make a …
70. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    June 19, 1986, the Court of Appeals affirmed our decision sub nom. Dillon v. United States, 792 F.2d 849 (9th Cir. 1986). The parties also stipulated: Petitioners accept the determination of tax contained in the deficiency notice as mathematically correct, except they contend that the tax should be computed by applying…
71. T.C. Summary Opinion 2017-51 — Arthur Dulik, Jr. & Ellen B. Kugler Dulik v. Commissioner
    IRCCourt RulingsJul 13, 2017related by meaning
    egard" includes any careless, reckless, or intentional disregard. Sec. 6662(c). Under section 7491(c), the Commissioner bears the burden of production with regard to penalties. See Higbee v. Commissioner, 116 T.C. 438, 446 (2001). 7The notice of deficiency reflected an increase in tax of $7,758. Petitioners' return as …