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61. T.C. Memo. 2012-344 — Karl E. Cross v. Commissioner
    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…
62. 151 T.C. No. 9 — David H. Melasky & Audrey Melasky v. Commissioner
    IRCCourt RulingsOct 10, 2018
    ry 27, 2011, check. The check did not clear, either because of the hold on petitioners' account (before February 28, 2011) or because the funds in the account had been transferred to the IRS (after February 28, 2011). Because petitioners' check did not clear, respondent reversed application of the check against their 2…
63. 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…
64. T.C. Summary Opinion 2007-129 — Jeffrey Lee Golian v. Commissioner
    IRCCourt RulingsJul 26, 2007related by meaning
    sioner , T .C . Memo . 2001-34 . We recognize that petitioner received his IRA distribution at a time when he was both a single parent and temporarily unemployed and that he used the distribution for a laudable purpose . Unfortunately for petitioner, we are bound by the lis t of statutory exceptions set forth in sectio…
65. T.C. Memo. 2012-44 — James Anthony Fonteneaux, Sr. v. Commissioner
    IRCCourt RulingsFeb 21, 2012related by meaning
    Respondent prepared decisiori.documents reflecting respolident's concessions of all issues for 2005 and a reduced deficiency;and addition to tax for . 2006. Petitioner repudiated the settlement and sought complete victöry and . sanctions against respondent based on "reckless professional behavior." Petitioner is frustr…
66. Rev. Proc. 2014-5 — Revised procedures are provided for furnishing technical advice to area managers and appeals office by the Office of the Division Commissioner, Tax Exempt and …
    IRCRevenue ProceduresJan 2, 2014related by meaning
    wed do not apply to requests for any documents to the extent §6104 applies. Statement identifying information to be deleted from public inspection .04 The text of a TAM subject to §6110(a) may be open to public inspection. The Service deletes certain information from the text before it is made available for inspection.…
67. 160 T.C. No. 3 — 3M Company and Subsidiaries v. Commissioner
    IRCCourt RulingsFeb 9, 2023related by meaning
    … and June 30, 1979), aff’d , 961 F.2d 1255 (6th Cir. 1992); and Exxon Cor p. v. Commissioner , T.C. Memo. 1993-616, 66 T.C.M. (CCH) 1707 (a case involving tax years 1979, 1980, and 1981), aff’d sub nom. Texaco, Inc. v. Commissioner , 98 F.3d 825 (5th Cir. 1996) In Procter & Gamble Co. v. Commissioner , 95 T.C. 323, 324…
68. T.C. Summary Opinion 2019-1 — Christopher John Totten v. Commissioner
    IRCCourt RulingsJan 29, 2019related by meaning
    made by the parties and, to the extent they are not addressed herein, we find them to be moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered under Rule 155.
69. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    …rief. We therefore believe that sanctions are appropriate. See, e.g., Randall v. Commissioner, T.C. Memo. 2008-138; Avery v. Commissioner, T.C. Memo. 2007-60, affd. 399 Fed. Appx. 195 (9th Cir. 2010). Pursuant to section 6673(a) (1), we impose against petitioner a penalty of $3,000. 7The amount of the sec. 6654 additio…
70. T.C. Memo. 2002-130 — Ray C. & Bernadette B. Baas v. Commissioner
    IRCCourt RulingsMay 29, 2002related by meaning
    … however, there was no levy by respondent in this case. Similarly, in Murillo v. Commissioner, T.C. Memo. 1998-13, affd. without published opinion 166 F.3d 1201 (2d Cir. 1998), also cited by petitioner, the taxpayer was indicted on charges of violating Federal currency transaction reporting laws. As part of the taxpaye…
71. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019related by meaning
    T.C. Summary Opinion 2019-26 PA UNITED STATES TAX COURT PASCAL NSAME AND LAMIAA MSALKA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11462-15S. Filed September 23, 2019. Pascal Nsame and Lamiaa Msalka, pro sese. Timothy B. Heavner and Mary Ann Waters, for respondent. SUMMARY OPINION COLVIN, Ju…
72. T.C. Memo. 2016-37 — Syed Navaid v. Commissioner
    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…
73. T.C. Memo. 2014-73 — Gina B. Weaver-Adams v. Commissioner
    IRCCourt RulingsApr 28, 2014related by meaning
    Mb-Mdf CMS T.C. Memo. 2014-73 UNITED STATES TAX COURT GINA B. WEAVER-ADAMS, Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13416-12. Filed April 28, 2014. Gina B. Weaver-Adams, pro se. Kimberly T. Packer, for respondent. MEMORANDUM OPINION KROUPA, Judae: Respondent détermined a $23,655' deficienc…
74. T.C. Memo. 1997-147 — David E. & Gladys A. Christie v. Commissioner
    IRCCourt RulingsMar 20, 1997related by meaning
    performed by anyone else. Discussion Petitioners bear the burden of establishing that respondent's determinations of deficiencies, as contained in the statutory notices of deficiency, are incorrect. Rule 142(a); Welch v. Helvering , 290 U.S. 111 (1933). Petitioners' briefs refer to several facts which were not included…
75. 109 T.C. No. 9 — Square D Company and Subsidiaries v. Commissioner
    IRCCourt RulingsOct 9, 1997related by meaning
    einafter referred to as the instant case). The instant case is before the Court on - 3 - 1 All Code and section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. the parties' cross-motions for partial summary judgment. …
76. 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…
77. U.S. Tax Court — Susan Elizabeth Machlay v. Commissioner
    IRCCourt RulingsFeb 10, 2009related by meaning
    ic v . ,Commissioner , T .C . Memo . 1992-- 609 ; sec . 1 .72-17A(f)(4), Income Tax Regs . . In 2006 petitioner discontinued the self-destructive life choices which had previously increased the severity of her medical condition . She explained at trial that although she received treatment from doctors in 2005, she did …
78. T.C. Memo. 1999-199 — Don Laverne Clarke v. Commissioner
    IRCCourt RulingsJun 18, 1999related by meaning
    1402(a). We therefore simply sustain respondent's determination as respondent did not assert an increased deficiency in this regard. See sec. 6214(a). used for retirement purposes, a 10 percent penalty is generally imposed on IRA distributions made before the taxpayer reaches age 59-1/2. See sec. 72(t). In that regard,…