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Go to 12 T.C. 348 (not yet in the library — opens the official source)
82 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 150 T.C. No. 7 — Celia Mazzei v. Commissioner
    IRCCourt RulingsMar 5, 2018related by meaning
    of petitioners' transactions. 3¹Purchase and entrance into all contracts were each conditioned on the other, and so we treat this as one step. - 37 - As illustrated above, it is true that sections 921-927 allowed a limited safe harbor from section 482 for the second part of petitioners' transactions--the commission pa…
  2. 114 T.C. No. 17 — Michael G. Bunney v. Commissioner
    IRCCourt RulingsApr 10, 2000
    …rson would do under the circumstances. See Allen v. Commissioner , 92 T.C. 1 (1989), affd. 925 F.2d 348 (9th Cir. 1991); Neely v. Commissioner , 85 T.C. 934, 947 (1985). The negligence accuracy-related penalty is inapplicable to any portion of an underpayment to the extent that an individual has reasonable cause for th…