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…
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…
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…
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(…
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…
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 …
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…
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…
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…
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…
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…
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…
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…
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…