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81. T.C. Summary Opinion 2002-66 — Milagros Z. Gueco v. Commissioner
    IRCCourt RulingsJun 10, 2002related by meaning
    T.C. Summary Opinion 2002-66 UNITED STATES TAX COURT MILAGROS Z. GUECO, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 545-01S. Filed June 10, 2002. Milagros Z. Gueco, pro se. James N. Beyer , for respondent. DINAN, Special Trial Judge : This case was heard pursuant to the provisions of section …
82. T.C. Memo. 2007-333 — Jeanne E. Amarasinghe v. Commissioner
    IRCCourt RulingsNov 6, 2007
    …79,368 as taxable income from pensions and annuities, and reported a deduction for alimony paid of $116,350 . In 2004, they filed a Form 1040X, Amended U .S . Individual Income Tax Return, for 2002 . On the Form 1040X, they removed th e $179,368 distribution from pensions and annuities income and the $116,350 deduction…
83. 80 T.C. 789; 80 T.C. No. 40 — Benson v. Commissioner
    IRCCourt RulingsApr 26, 1983related by meaning
    attributable to tax advice. Petitioner has made no attempt to meet this burden; accordingly, on this record we must uphold respondent’s determination. Issue 3. Capital Loss Carryover A taxpayer claiming a capital loss carryover must be able to establish that he actually incurred the loss he wishes to carry over. The on…
84. 116 T.C. No. 13 — Kenneth L. Nordtvedt v. Commissioner
    IRCCourt RulingsMar 13, 2001
    116 T.C. No. 13 UNITED STATES TAX COURT REC ED -SERVIC CAL. I Wüs KENNETH L. NORDTVEDT, Petitioner y. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 670-99. Filed March 13, 2001. P adjusted the basis in his retirement annuity by an inflation factor, to take account of inflation betweeñ the date of his contribu…
85. T.C. Memo. 2012-36 — Lisa LaFlamme v. Commissioner
    IRCCourt RulingsFeb 6, 2012
    …t 310. - 10 - appropriate to impose the relevant penalty. See.sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446 (2001). We find that respondent has met his burden of production. The accuracy-related penalty is not imposed.with respect to any portion of the underpayment as to which the taxpayer shows that he or sh…
86. T.C. Memo. 2010-115 — Ronald D. & Lorie A. Jelling v. Commissioner
    IRCCourt RulingsMay 27, 2010related by meaning
    entitled to the reasonable cause and goo d faith defense under section 6664 because they did not act reasonably in relying on their accountants . 60 - Petitioners argue that the complexity of the cases and the .first-impression issues presented justify abatement of the accuracy-related penalty . This is not an issue of…
87. T.C. Memo. 2020-152 — Brett John Ball v. Commissioner
    IRCCourt RulingsNov 10, 2020
    … to the liability of any individual for penalties and additions to tax. See Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). - 12 - [*12] "In order to meet the burden of production under section 7491(c), the Commissioner need only make a prima facie case that imposition of the penalty or addition to tax is appropr…
88. T.C. Memo. 2017-139 — Louelia Salomon Frias & Mervyngil Salomon v. Commissioner
    IRCCourt RulingsJul 11, 2017
    … indicating that it is appropriate to impose the penalty. See sec. 7491(c); Higbee v. Commissioner, 116 T.C. at 446-447. Once the Commissioner meets his burden of production, the taxpayer must come forward with persuasive evidence that the Commissioner's determination is incorrect or that the taxpayer had reasonable ca…
89. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013related by meaning
    T.C. Summary Opinion 2013-96 UNITED STATES TAX COURT SAMUEL BRACH AND LILLIAN BRACH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15460-12S. Filed December 2, 2013. Ronald Jay Cohen, for petitioners. Gennady Zilberman, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was h…
90. T.C. Memo. 2016-215 — Glen A. Blair v. Commissioner
    IRCCourt RulingsNov 23, 2016
    …015); Bunney v. Commissioner, 114 T.C. 259, 265 (2000). ¹°See sec. 7491(c); Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). "Sec. 6651(a)(1); Higbee v. Commissioner, 116 T.C. at 446-447. - 8 - [*8] income greater than the exemption amount. He is required to file a return.¹² He did not raise any other defenses. Ac…
91. 141 T.C. No. 19 — Andrew Wayne Roberts v. Commissioner
    IRCCourt RulingsDec 30, 2013related by meaning
    ss otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are (continued...) - 3 - deficiency of $14,177 and an increased accuracy-related penalty of $3,435. A…
92. T.C. Memo. 2015-128 — James Boneparte, Jr. v. Commissioner
    IRCCourt RulingsJul 13, 2015
    … regarding the taxpayer's liability for any penalty. Sec. 7491(c); see also Higbee v. Commissioner, 116 T.C. 438, 446-447 (2001). Once the Commissioner has met this burden, the taxpayer must provide persuasive evidence that the Commissioner's determination was incorrect. See Rule 142(a); Higbee v. Commissioner, 116 T.C…
93. T.C. Summary Opinion 2005-62 — Thomas Richard & Donna Estes White v. Commissioner
    IRCCourt RulingsMay 23, 2005related by meaning
    1 Unless otherwise indicated, all subsequent section references are to the Internal Revenue Code in effect for 2001, the taxable year in issue. All monetary amounts are rounded to the nearest dollar. T.C. Summary Opinion 2005-62 UNITED STATES TAX COURT THOMAS RICHARD WHITE AND DONNA ESTES WHITE, Petitioners v . COMMISS…
94. 89 T.C. 287; 89 T.C. No. 25 — Larotonda v. Commissioner
    IRCCourt RulingsAug 13, 1987related by meaning
    …ed in part on petitioners’ failure to include the $53 of interest income in their 1981 income. Sec. 116 allows individuals to exclude $200 of dividend and interest income ($400 for a married couple filing jointly) from gross income. Hence, the omission of the $53 interest income did not result in an understatement of p…