IRCCourt RulingsSep 13, 2010
Memo . 1997-331 ; Speer v .
Commissioner
Memo . 1993- 5
The fol
accuracy of
appears exce
amount of ti
(2) the Geor
during 2004 .
Further
petitioner c T .C . Memo . 1996-323 ; Goshorn v . Commissioner , T .C .
1 8 .
owing factors further diminish the credibility and
etitioner's claim : (1) The number of hours claimed
~…
IRCCourt RulingsMay 14, 2009related by meaning
…we hold that petitioners are not entitled to the charitable contribution deduction claimed on their 2004 Federal
income tax return .
Section 6673 Penalt y
Respondent requests imposition of a penalty pursuant to
section 6673 . Section 6 .673(a)(1)(A) authorizes the Tax Court to
require a taxpayer to pay to the' United S…
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 RulingsJan 3, 2011related by meaning
…of $6,134, for a total of $97,134. Petitioner's life
insurance policy was decreased during 2003 and 2004 for mortality charges of $16,235 and other expenses of $10,370, respectively,
for a total of $26, 605. As noted above, petitioner' s interest in
the life insurance policy is not' reduced by any surrender
charges . A…
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 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 RulingsNov 1, 2005related by meaning
…d all Rule references
are to the Tax Court Rules of Practice and Procedure. All
(continued...)
T.C. Memo. 2005-258
UNITED STATES TAX COURT
JOYCE M. THOMAS, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10824-03. Filed November 1, 2005.
Joyce M. Thomas, pro se.
Andrew R. Moore
, for respondent.
…
IRCCourt RulingsNov 7, 2003related by meaning
1
Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year at issue.
T.C. Summary Opinion 2003-161
UNITED STATES TAX COURT
MARTIN EDWARD CAULFIELD, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19485-02S. Filed November 7, 2003.
Martin Ed…
IRCCourt RulingsJun 6, 2019related by meaning
DRC
T.C. Memo. 2019-67
UNITED STATES TAX COURT
MARIA SHENORAH MCCREE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10129-14L. Filed June 6, 2019.
Maria Shenorah McCree, pro se.
Moenika N. Coleman, Linda L. Wong, Michael S. Navarro, and Cindy L.
Wofford, for respondent.
MEMORANDUM FINDINGS OF FA…
IRCCourt RulingsOct 21, 2003related by meaning
1
Unless otherwise indicated, subsequent section
references are to the Internal Revenue Code in effect for the
year at issue.
T.C. Summary Opinion 2003-157
UNITED STATES TAX COURT
DARRELL R. FULCHER, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14140-01S. Filed October 21, 2003.
Darrell R. Ful…
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…