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Go to T.C. Memo. 2004-269 (not yet in the library — opens the official source)
74 documents · 0.21sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2008-204 — Walter Kowsh v. Commissioner
    IRCCourt RulingsAug 28, 2008related by meaning
    T .C . Memo . 2008-20 4 UNITED STATES TAX-COUR T WALTER KOWSH, Petitioner v . COMMISSIONER OF . INTERNAL . REVENUE, Responden t Docket No . 15154-06 . Filed August 28, 2008 . Walter Kowsh, pro se . Michelle L . Maniscalco , for respondent . MEMORANDUM FINDINGS'-OF-FACT-AND OPINIO N KROUPA, Judge : Respondent determined…
  2. T.C. Memo. 1998-42 — William C. Reichenbach v. Commissioner
    IRCCourt RulingsFeb 4, 1998related by meaning
    ng warned by the Court and after having received notice from the Court in a prior case. 6 On the basis of the record, we conclude that the proceedings herein were instituted primarily for delay and that petitioner's position is both frivolous and groundless. Accordingly, we exercise our discretion and award a penalty t…
  3. T.C. Memo. 2004-11 — Graceann Berry v. Commissioner
    IRCCourt RulingsJan 12, 2004related by meaning
    ng documentation - 5 - was questionable considering the fact that the documents she did provide to the Court would have been part of the documents she claimed to have discarded due to the alleged sewage problem. Petitioner’s argument must fail for failure to show that the amount that should be excepted under section 72…
  4. 162 T.C. No. 4 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsFeb 28, 2024related by meaning
    stituting a 6-year period in lieu of the 3-year period otherwise referred to in such subsection. (D) Exception for certain acquisitions of property. — In the case of any tax imposed by section 4973 that is attributable to acquiring property for less than fair market value, subparagraph (A) shall not apply. Section 313(…
  5. T.C. Memo. 2020-38 — Ronald M. Goldberg v. Commissioner
    IRCCourt RulingsApr 2, 2020
    … "supposed to make any other assessments [of tax] for that year." The examination of the Goldbergs' 2004 tax year could yield deficiencies and additions to tax, which would in turn lead to assessments of tax. If the IRS accepted Goldberg's pending offer-in-compromise while the 2004 examination was still taking place, t…
  6. 98 T.C. 141; 98 T.C. No. 12 — Truck & Equipment Corp. v. Commissioner
    IRCCourt RulingsFeb 6, 1992related by meaning
    Parker, Judge: By statutory notice of deficiency dated May 17, 1989, respondent determined a deficiency in petitioner's Federal income taxes and additions to tax as follows: _Additions to tax_ Sec. Sec. Sec. TYE Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661 1/31/86 $64,117 $3,206.85 50 percent $16,029.25 of the interest …
  7. T.C. Memo. 1995-599 — Rhett B. & Sandra L. Ross v. Commissioner
    IRCCourt RulingsDec 19, 1995
    …fer Refund does not constitute a qualified total distribution. See Wittstadt v. Commissioner , T.C. Memo. 1995492; Humberson v. Commissioner , T.C. Memo. 1995-470; Pumphrey v. Commissioner , T.C. Memo. 1995-469 ; Adler v. Commissioner , T.C. Memo. 1995-148; Dorsey v. Commissioner , T.C. Memo. 1995-97; Brown v. Commissi…
  8. T.C. Summary Opinion 2007-180 — Suzanne E. Barrera, a.k.a. Suzanne E. Battle v. Commissioner
    IRCCourt RulingsOct 24, 2007
    …eturn. See, e.g., Hopkins v. Commissioner , 121 T.C. 73, 88-89 (2003); Knorr v. Commissioner , T.C. Memo. 2004-212; Morello v. Commissioner , T.C. Memo. 2004-181; Keitz v. Commissioner , T.C. Memo. 2004-74; Ogonoski v. - 35 - Commissioner , T.C. Memo. 2004-52; Wiest v. Commissioner , T.C. Memo. 2003-91; see also Rev. P…
  9. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018related by meaning
    …for the determination may reasonably be discerned, 2¹(...continued) for 2000, 2001, 2002, 2003, and 2004 were sufficient to absorb the levy proceeds. That is, even if the period of limitations on collection for the 1995 and 1996 income tax liabilities had expired, the proceeds of the levy would not have been applied ag…
  10. 132 T.C. No. 15 — Gregory T. & Kim D. Benz v. Commissioner
    IRCCourt RulingsMay 11, 2009
    …ry 1 5 each year for a period based on petitioner wife's life expectancy . On or-before January 15, 2004, petitioner wife received a $102,311 .50 distribution from her IRA in accordance with-her election to receive a series of-substantially equal periodic payments . During 2004 petitioner wife received two additional d…
  11. T.C. Memo. 2010-149 — Harold X. O'Boyle v. Commissioner
    IRCCourt RulingsJul 13, 2010related by meaning
    all of the contentions and arguments of the parties that are not discussed herein, and we conclude that they are without merit, irrelevant, or moot . "Para . 6 of the petition filed by each petitioner admits : "According to Section 6673, this court may penalize Petitioner up to $25,000 for failure to complete the admin…
  12. T.C. Memo. 2003-223 — Richard Wos v. Commissioner
    IRCCourt RulingsJul 29, 2003related by meaning
    bmitted a document to the Court entitled “Trial Memorandum of Petitioner” that the Court had filed (petitioner’s trial memorandum). Petitioner’s trial memorandum contained various statements, contentions, and arguments with respect to what constitutes income for tax purposes that the Court found in an Order dated March…
  13. Rev. Proc. 2005-25 — Fair market value; distributions; qualified retirement plans. This procedure provides guidance, including examples, of how fair market value may be determined …
    IRCRevenue ProceduresApr 25, 2005
    …evenue procedure applies to distributions, sales, and other transfers made on or after February 13, 2004, to permanent benefits within the meaning of § 1.79-0 provided on or after February 13, 2004, and to non-exempt employees’ trusts under § 402(b) for periods on or after February 13, 2004. However, for periods before…
  14. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    IRCCourt RulingsDec 11, 1997related by meaning
    ng bank at the end of 1992. Based on our examination of the entire record before us, we find that petitioners have failed to show that they acted with reasonable cause and in good faith, or that they otherwise exercised due care or made a reasonable attempt to comply with the Code, when they claimed the 1992 and 1993 d…