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61. 142 T.C. No. 21 — Whistleblower 11332-13W v. Commissioner
    IRCCourt RulingsJun 4, 2014related by meaning
    hey would establish that respondent proceeded against the targets using information the whistleblower provided after December 20, 2006. If these facts are established, the whistleblower is entitled to judicial review of respondent's award determination. We hold, consistent with the rationale of Dacosta, that this Court…
62. Notice 2013-2 — Weighted average interest rate update; corporate bond indices; 30-year Treasury securities; segment rates. This notice contains updates for the corporate bond …
    IRCNoticesFeb 4, 2013
    …Segment Rates First Segment Second Segment Third Segment 1.62 4.40 5.45 For plan years beginning in 2012, the 24-month average segment rates determined under § 430(h)(2)(C)(iv) must be not less than 90% nor greater than 110% of the 25-year average segment rates. Pursuant to Notice 2012-55, 2012-36 I.R.B. 332, the first…
63. T.C. Memo. 1996-365 — Timothy W. & Suzanne M. Coffield v. Commissioner
    IRCCourt RulingsAug 8, 1996related by meaning
    to the Internal Revenue Code by section 302 of the Taxpayer Bill of Rights 2, Pub. L. 104-168, authorizes this Court to review the Secretary's failure to abate interest with respect to requests for abatement after July 30, 1996. Because this case does not involve a request for abatement after July 30, 1996, we lack jur…
64. 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…
65. T.C. Memo. 2017-112 — Whistleblower 19860-15W v. Commissioner
    IRCCourt RulingsJun 13, 2017related by meaning
    and after the effective date of section 7623(b). See Whistleblower 1133213W v. Commissioner, 142 T.C. 396. In that case we held that the determinative issue is whether the whistleblower alleged facts that, if proven, would establish that the Commissioner proceeded against the targets using information that the whistleb…
66. T.C. Memo. 2023-141 — Danielle Monique Scott v. Commissioner
    IRCCourt RulingsNov 28, 2023related by meaning
    tion she received in 2019. ” Petitioner did not respond t o our Order by the October 2, 2023, deadline or subsequently. Discussion I. Summary Judgment The purpose of summary judgment is to expedite litigation and avoid costly, time-consuming, and unnecessary trials. Fla. Peach Corp. v. Commissioner , 90 T.C. 678, 681 (…
67. T.C. Memo. 2019-145 — Jane M. Lassek, Petitioner and Michael E. Smith, Intervenor v. Commissioner
    IRCCourt RulingsOct 28, 2019
    …collection action. Petitioner concedes that she is liable for the overreported income tax withheld. 2012 Underpayment In 2012 petitioner took an $11,000 taxable distribution from her section 401(k) retirement plan account, and intervenor took a $23,510 distribution from his section 401(k) retirement plan account, $23,4…
68. 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…
69. T.C. Memo. 2012-166 — Todd R. & Andrea Pedersen v. Commissioner
    IRCCourt RulingsJun 13, 2012related by meaning
    ion of the stock in an S corporation), nor the penalties determined by respondent. - 27 - For the reasons stated, Appropriate orders will be issued in docket Nos. 6000-09 and 6449-09, and decisions will be entered for petitioners in docket Nos. 5999-09., 6290-09, 6303-09, and 12128-09.
70. T.C. Memo. 2016-182 — Dora Marie Martinez & Carlos Garcia v. Commissioner
    IRCCourt RulingsSep 28, 2016
    … or - 5 - [*5] erroneous. See Hardy v. Commissioner, 181 F.3d 1002, 1004-1005 (9th Cir. 1999), T.C. Memo. 1997-97; Tokarski v. Commissioner, 87 T.C. 74, 76-77
71. T.C. Memo. 2010-200 — Cheryl Elizabeth & Don Edward Hill v. Commissioner
    IRCCourt RulingsSep 13, 2010related by meaning
    … a matter which is within the discretion of the Commissioner . . Colvin v . . Commissioner , T .C . Memo . 2004-67, affd . 122 Fed . Appx . 788 (5th Cir . 2005) . Furthermore,petitioners have failed to identify a ministerial or managerial delay by an IRS employee that cause d ,them to forgo making payments on their . i…
72. T.C. Memo. 2017-139 — Louelia Salomon Frias & Mervyngil Salomon v. Commissioner
    IRCCourt RulingsJul 11, 2017
    ommissioner, T.C. Memo. 1995-421. Section 1.72(p)-1, Q&A-10(a), Income Tax Regs., provides that ordinarily the failure to make any installment payment when due7 violates the substantially level amortization requirement. However, the substantially level amortization requirement is not violated so long as a payment, even…
73. T.C. Memo. 2015-61 — Kevin R. Gurule & Dawn M. Gurule v. Commissioner
    IRCCourt RulingsMar 31, 2015related by meaning
    Commissioner's determination for abuse of discretion. E2, Sego v. - 18 - [*18] Commissioner, 114 T.C. at 610. The Appeals Office abuses its discretion when its exercise of discretion is arbitrary, capricious, or without sound basis in fact or law. Murphy v. Commissioner, 125 T.C. 301, 308, 320 (2005), aff'd, 469 F.3d 2…
74. T.C. Memo. 2019-67 — Maria Shenorah McCree v. Commissioner
    IRCCourt RulingsJun 6, 2019related by meaning
    ng a deficiency after issuing a refund. McCree v. Commissioner, at *18-*20. It is clear from our review of the record that SO Taylor verified that the requirements of any applicable law and administrative procedure were followed - 20 - [*20] and that in sustaining the proposed levy against petitioner, SO Taylor properl…
75. Rev. Proc. 2025-3 — The revenue procedure updates Rev. Proc. 2024-3, 2024-1 I.R.B.143, to provide a revised list of areas under the jurisdiction of the Associate Chief Counsel (Co…
    IRCRevenue ProceduresDec 30, 2024related by meaning
    ng in a change in beneficial interests causes the loss of GST exempt status or constitutes a taxable termination or taxable distribution under § 2612. (18) Sections 4966 and 4967.—Taxes on Taxable Distributions; Taxes on Prohibited Benefits.—Issues involving interpretation of §§ 4966 and 4967 regarding distributions fr…
76. T.C. Memo. 2021-105 — Sherrie L. Webb v. Commissioner
    IRCCourt RulingsAug 31, 2021related by meaning
    including granting CNC status - - s ince petitioner did not furnish necessary documentation. On the basis of these circumstances M s. Rego performed a balancing test, concluding that the proposed levy did balance the needs of collection with the concerns of petitioner. On the basis of our review w e hold that M s. Rego…
77. 79 FR 10296 — Ninety-Day Waiting Period Limitation and Technical Amendments to Certain Health Coverage Requirements Under the Affordable Care Act
    IRCFinal Rules (FR)Feb 24, 2014
    …(3)(iii), and 45 CFR 146.111(a)(3)(iii). Back to Citation 4.  Department of Labor Technical Release 2012-01, IRS Notice 2012-17, and HHS FAQs issued February 9, 2012. Back to Citation 5.  Department of Labor Technical Release 2012-02, IRS Notice 2012-59, and HHS FAQs issued August 31, 2012. Back to Citation 6.   See 26…
78. T.C. Memo. 2012-221 — Robert L. Bernard & Diolinda B. Abilheira v. Commissioner
    IRCCourt RulingsAug 1, 2012related by meaning
    4, 2011, but was continued on petitioners' motion so that the parties could determine the amounts of nondeductible contributions to the IRAs. The case was continued to March 23, 2011, but was thereafter continued again on petitioners' motion so that they could take a trip out of the country. By notice served May 9, 201…