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81. 108 T.C. No. 25 — Billy & Ruth Johnson v. Commissioner
    IRCCourt RulingsJun 17, 1997related by meaning
    he penalties in docket Nos. 2545-94 and 9230-94; an appropriate decision for respondent will be entered in docket No. 5754-94 as to the deficiency and the addition to tax under section 6651(a)(1) and for petitioner with respect to the penalty .
82. T.C. Memo. 2026-89 — Whistleblower 6417-20W v. Commissioner
    IRCCourt RulingsSep 17, 2026related by meaning
    n effect at all relevant times, regulation references are to the Code of Federal Regulations, Title 26 (Treas. Reg.), in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure. Served 09/17/26 2 [* 2 ] there were no changes in the IRS approach to the issue after review of…
83. Treas. Reg. § 1.408-2(e)(5)(ii)(D) — Individual retirement accounts.
    IRCRegulationsMay 18, 2016
    …uals $164,000; (2) two percent of $1,400,000 equals $28,000; and (3) $164,000 minus $28,000 equals $136,000. Thus, because $136,000 exceeds $100,000, the minimum net worth necessary for Trustee X to accept new accounts for 1996 is $136,000.(d) For 1996, the amount determined under § 1.408-2(e)(5)(ii)(C) for Trustee X i…
84. T.C. Memo. 1997-545 — French E. & Janice C. Hickman v. Commissioner
    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…
85. T.C. Memo. 1998-318 — Howard E. Clendenen, Inc. v. Commissioner
    IRCCourt RulingsSep 3, 1998related by meaning
    in participant's compensation, effective for years beginning after Dec. 31, 1997. This amendment does not apply to the instant case. We note, however, that the legislative history makes clear that Congress considered the provisions of the then-existing law as requiring the result reached herein and specifically intende…
86. T.C. Memo. 2011-104 — Patricia Louise Hyde v. Commissioner
    IRCCourt RulingsMay 19, 2011related by meaning
    SE AGI adjustment (6,535) Standard deduction (5,150) Exemptions (3,300) Corrected taxable income1 89,936 Respondent used a filing status of "single". In response to the notice of deficiency, petitioner petitioned the Court on April 7, 2010. A trial was held on January 11, 2011. OPINION I. Validity of the Notice of Def…
87. T.C. Memo. 1998-245 — Richard Raymond Raush v. Commissioner
    IRCCourt RulingsJul 6, 1998related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1998-247 UNITED STATES TAX COURT HERMAN E. AND SHERI L. VILLARROEL, Petitioners v . COMMISSIONER OF INTERNAL…
88. T.C. Memo. 1997-199 — David W. Chiu v. Commissioner
    IRCCourt RulingsApr 30, 1997related by meaning
    itioner can show that he comes within one of the exceptions of section 6654(e). Hudson v. Commissioner , 103 T.C. 90, 110 (1994), affd. without - 26 - published opinion 71 F.3d 877 (5th Cir. 1995). Petitioner bears the burden of proof on this issue, Baldwin v. Commissioner , 84 T.C. 859, 871 (1985), and the record cont…
89. 136 T.C. No. 6 — Michael P. Schwab & Kathryn J. Kleinman v. Commissioner
    IRCCourt RulingsFeb 7, 2011
    $136,000 a year; for - Kleinman, it was $120,000. In some of the-ilslustrations that the insurance company used, Angels & Cowboys would be paying such premiums for decades; in some, the firm would make pay premiums , for only ten years. But we find that the firm paid the premiums only for the policies' first year.5 The…
90. T.C. Memo. 2007-292 — Hubert Joubert v. Commissioner
    IRCCourt RulingsSep 24, 2007related by meaning
    )(2) addition to tax . The sec . 6651(a)(2) addition to tax was listed only in the Form 4549, Income Tax Examination Changes, which was included as an attachment to the notice of deficiency . Suffice it to note that respondent raised the sec . 6651(a)(2) addition to tax in his answer, albeit while misciting that sectio…
91. T.C. Memo. 2012-344 — Karl E. Cross v. Commissioner
    IRCCourt RulingsDec 13, 2012related by meaning
    … The IPetitioner's motion is premised on the principles set forth in Scar v. Commissioner, 814 F.2d 1363 (9th Cir. 1987), rev'g 81 T.C. 855 (1983). SERVEDDec132012 - 2 - [*2] issue to be decided concerns the validity of the notice of deficiency and whether respondent "determined" a deficiency in petitioner's 2004 Feder…
92. T.C. Memo. 2017-3 — Candace Elaine v. Commissioner
    IRCCourt RulingsJan 3, 2017related by meaning
    v. Commissioner, T.C. Memo. 1996-354); Milner v. Commissioner, T.C. Memo. 2004-111; Gallagher v. Commissioner, T.C. Memo. 2001-34; Robertson v. - 8 - [*8] Commissioner, T.C. Memo. 2000-100, af[d, 15 F. App'x 467 (9th Cir. 2001). While we acknowledge and are sympathetic to petitioner's financial straits, we have no aut…
93. T.C. SUMMARY OPINION 2020-12 — Edwin D. Benton & Sheila E. Benton v. Commissioner
    IRCCourt RulingsMar 11, 2020related by meaning
    fter concessions,2 the issues remaining for decision are whether petitioners are (1) entitled to deductions claimed on Schedule C, Profit or Loss From Business, for various expenses, (2) liable for the 10% additional tax imposed on ¹(...continued) Revenue Code, as amended and in effect for 2013, and Rule references are…