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69 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 1999-80 — Edward Clasby and C. T. Garrahan Insurance Agency, Inc. v. Commissioner
    IRCCourt RulingsMar 16, 1999related by meaning
    ansaction. Any disqualified person who participates in a prohibited transaction is liable for the tax. Sec. 4975(a). A - 11 - 2 Sec. 4975(e) provides: SEC. 4975(e). Definitions.-- * * * * * * * (2) Disqualified person.--For purposes of this section, the term "disqualified person" means a person who is-- (A) a fiduciary…
  2. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019related by meaning
    ng a taxable year equals $250 or more." Sec. 1.170A-13(f)(1), Income Tax Regs. 9Sec. 170(f)(8)(D) provides an exception to the contemporaneous written acknowledgment requirement. Petitioner does not assert that this exception applies. - 29 - due date, including extensions, for filing that tax return. Sec. 170(f)(8)(C).…
  3. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    yer's return information. None of the assertions, even if true, would affect petitioners' deficiency. Petitioners' attacks on the Court in relation to its Rules of Practice and Procedure and the rulings in this and other cases lack merit and will not be addressed in this opinion. Adverse rulings are not grounds - 8 - […
  4. T.C. Memo. 2011-253 — George R. Ward, Petitioner and Victoria J. Ward, Intervenor v. Commissioner
    IRCCourt RulingsOct 31, 2011related by meaning
    iles a joint return is computed by aggregating the two incomes and that their income-tax liability is joint and several. Section 6015(a) provides that notwithstanding section 6013(d) (3) a person who files a joint return is relieved of joint liability under three specific exceptions set forth in section 6015(b), (c), a…
  5. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    e Commissioner's determinations are erroneous, see Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). This burden of production remains on the taxpayer even with respect to the additional tax under section 72(t) because the section 72(t) additional tax is a "tax" and not a "penalty, addition to tax, or addition…
  6. T.C. Memo. 1998-336 — Robert A. & Laverne M. Hall v. Commissioner
    IRCCourt RulingsSep 22, 1998related by meaning
    te minus amounts received before such date to the extent excludible from gross income. Sec. 72(e)(6). The remainder of petitioner's distribution after determination of the nontaxable amount represents the payment to him of income and as the parties have agreed is subject to the 10-percent premature distribution tax und…
  7. T.C. Summary Opinion 2005-10 — Jerome P. & Rhonda A. Reimann v. Commissioner
    IRCCourt RulingsJan 27, 2005related by meaning
    the deficiency in this case. With respect to petitioners' first contention, as noted earlier, section 72(t)(2) excepts from the additional tax certain categories of distributions. Petitioners agree that none of these categories apply to their fact situation. Instead, petitioners contend that, because of financial hards…
  8. 146 T.C. No. 7 — James E. Thiessen & Judith T. Thiessen v. Commissioner
    IRCCourt RulingsMar 29, 2016related by meaning
    or an increased deficiency, which means that we will not enter in our decision a deficiency greater than that shown in the deficiency notice. See sec. 6214(a); Estate of Petschek v. Commissioner, 81 T.C. 260, 271-272 (1983), afCd, 738 F.2d 67 (2d Cir. 1984); see also Koufman v. Commissioner, 69 T.C. 473, 475476 (1977).…
  9. T.C. Memo. 2023-141 — Danielle Monique Scott v. Commissioner
    IRCCourt RulingsNov 28, 2023related by meaning
    ity. Because she failed to respond to that request , she is deemed to have admitted receiving taxable income in the relevant amounts . See Rule 90(c). Th ese deemed admission s alone suffice to establish that no genuine dispute exists as to the issue of unreported income. See Marshall , 85 T.C. at 272– 73. We according…