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
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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…
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.
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due date, including extensions, for filing that tax return. Sec. 170(f)(8)(C).…
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
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[…
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…
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…
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…
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…
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).…
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…