IRCCourt RulingsDec 13, 2012related by meaning
CLC
T.C. Memo. 2012-344
UNITED STATES TAX COURT
KARL E. CROSS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6009-09. Filed December 13, 2012.
Mitchell Stuart Fuerst and Joseph A. DiRuzzo III, for petitioner.
Brian E. Derdowski, Jr., and Carroll De Groff Lansdell, for respondent.
MEMORANDUM OPIN…
84 FR 56894 — Default Electronic Disclosure by Employee Pension Benefit Plans Under ERISA ERISAProposed Rules (FR)Proposed Oct 23, 2019
…ections 401(k)(13)(E) and 414(w)(4) for automatic contribution arrangements.
(iv) Technical Release 2011-03R On December 8, 2011, the Department issued Technical Release 2011-03R (TR 2011-03R), which sets forth an interim enforcement policy regarding the use of electronic media to satisfy the disclosure requirements un…
IRCCourt RulingsApr 10, 2018related by meaning
JRN
T.C. Memo. 2018-49
UNITED STATES TAX COURT
STACEY S. MARKS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18520-16. Filed April 10, 2018.
Ray C. Mayo, Jr., for petitioner.
Donielle A. Hubbard, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
MORRISON, Judge: Respondent mailed petition…
IRCCourt RulingsMay 8, 2006related by meaning
002, it could not have been determined
whether petitioner had any overpayment with respect to taxable
year 2002.
petitioner’s overpayment for 2001.
10 The disallowance of the
credit that petitioner claimed with respect to this item does not
affect the amount of petitioner’s deficiency for 2002. See sec.
6211(a) (defini…
IRCCourt RulingsJun 25, 2013related by meaning
T.C. Summary Opinion 2013-51
UNITED STATES TAX COURT
MARTIN TOOMBS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 27665-10S. Filed June 25, 2013.
James O. Creech III, for petitioner.
Thomas D. Yang, for respondent.
SUMMARY OPINION
ARMEN, Special Trial Judge: This case was heard pursuant to the
p…
IRCCourt RulingsNov 30, 2006related by meaning
1
Unless otherwise indicated, all subsequent section
references are to the Internal Revenue Code in effect for 2002,
the taxable year in issue.
T.C. Summary Opinion 2006-184
UNITED STATES TAX COURT
WILLIAM EDWARD AND PATRICIA MARIE COLOMBELL, Petitioners v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23979…
IRCCourt RulingsJul 8, 2020related by meaning
BD
T.C. Memo. 2020-101
UNITED STATES TAX COURT
TAMECCA SERIL, a.k.a. TAMECCA TILLARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4491-19. Filed July 8, 2020.
Tamecca Seril, a.k.a. Tamecca Tillard, pro se.
Marissa J. Savit and Thomas A. Deamus, for respondent.
MEMORANDUM FINDINGS OF FACT AND O…
IRCCourt RulingsJan 13, 1999related by meaning
T.C. Memo. 1999-4
UNITED STATES TAX COURT
THOMAS MARK PEASLEE, Petitioner v
.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8582-97. Filed January 13, 1999.
Thomas Mark Peaslee, pro se.
James A. Whitten
, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GOLDBERG, Special Trial Judge
: This case was hea…
IRCCourt RulingsMar 3, 2016related by meaning
KVC
T.C. Memo. 2016-37
UNITED STATES TAX COURT
SYED NAVAID, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 328-13. Filed March 3, 2016.
James O. Creech, III and Jane Zhao, for petitioner.
Alexander R. Roche, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARIS, Judge: Respondent determin…
IRCCourt RulingsNov 1, 2005related by meaning
bilateral tendinitis, carpal
tunnel syndrome, and depression at the time the estimated
payments were required to be made. However, during this period, petitioner was employed by Cypress and was running her own
startup network marketing business. We find that petitioner was
not disabled for purposes of section 6654. The…
IRCCourt RulingsFeb 12, 2008related by meaning
oner ,
T .C . Memo . 2004-125 .
- 6 -
Petitioner has not argued, and she has failed to
demonstrate, that she is a member of any suspect classification or that TRHCA section 408 interferes with a fundamental right .
Consequently, we must uphold TRHCA section 408 if it bears a
rational relationship to a legitimate govern…
IRCCourt RulingsJan 17, 2024related by meaning
Title 26 U.S.C. (Code) , in effect at all relevant times, and Rule references are to
the Tax Court Rules of Practice and Procedure .
Served 01/17/24
2 [* 2 ] deficiencies under section 4973 in th e aggregate amount of
$8,476,705 . The notices also determined additions to tax under section
6651(a)(1) and (2) and accurac…
T.C. Memo. 2016-10 — Family Chiropractic Sports Injury & Rehab Clinic, Inc. v. Commissioner IRCCourt RulingsJan 19, 2016related by meaning
MN
T.C. Memo. 2016-10
UNITED STATES TAX COURT
FAMILY CHIROPRACTIC SPORTS INJURY & REHAB CLINIC, INC.,
Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 29613-13R. Filed January 19, 2016.
Richard W. Leavitt (an officer) and Mark Eldridge (trustee), for petitioner.
Shawn P. Nowlan, for respondent.
MEM…
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 RulingsJun 26, 2017related by meaning
e requirements of the QDRO provisions must be "rigidly observed"
because they "relate to the substance or essence of the statute"). We have con-
- 8 - [*8] siderable sympathy for petitioner's position: In effect, his willingness to help
minimize stress on his soon-to-be ex-wife disabled him from satisfying the
statutor…
IRCCourt RulingsJul 25, 2012related by meaning
…ed annual payment for 2006
was 90% of the tax for that year. See id.; Missall v. Commissioner, T.C. Memo.
2008-258, 2008 Tax Ct. Memo LEXIS 254, at *7-8. Respondent has met his
burden of production for the section 6654 addition to tax.
The "section 6654 addition to tax is mandatory unless the taxpayer
establishes that …