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86 documents · 0.19sAllIRCERISAPBGCJoint Board
  1. 66 T.C. 324 — Bianchi v. Commissioner
    IRCCourt RulingsMay 20, 1976related by meaning
    nd nondeferred compensation must be subject to the reasonable allowance standards set forth in section 162(a)(1). Sec. 1.404(a)-1(b), Income Tax Regs. Petitioners contend that if Congress intended section 404(a) to be subject to reasonable compensation standards, it would have specifically mentioned section 162(a)(1). …
  2. T.C. Memo. 2024-16 — Lonnie Wayne Hubbard v. Commissioner
    IRCCourt RulingsFeb 6, 2024
    …ity and no tax liability, did not meet the requirements of section 6020(b). In Cabirac, 120 T.C. at 172, the Commissioner asserted that a notice of proposed adjustment s which contained information as to how the taxpayer’s tax liability was computed was in the record; however, the Commissioner did not introduce any evi…
  3. T.C. Memo. 1999-4 — Thomas Mark Peaslee v. Commissioner
    IRCCourt RulingsJan 13, 1999
    …itioner's bank account because petitioner failed to pay his 1993 Federal income tax liability of $4,172 as shown on his return. At that time, 5 the IRS apparently determined a "fine" or "penalty" in regard to the $4,172 amount. In contesting all "unlawful fines and/or penalties" in his petition to this Court, petitione…
  4. T.C. Memo. 2017-5 — Brian E. Harriss v. Commissioner
    IRCCourt RulingsJan 5, 2017related by meaning
    Federal income tax return on or before the payment due date unless such failure is due to reasonable cause and not due to willful neglect. The section 6651(a)(2) addition to tax applies only when an amount of tax is shown on a return filed by the taxpayer or prepared by the Secretary. Sec. 6651(a)(2), (g)(2); Cabirac v…
  5. T.C. Memo. 2016-172 — Bonita L. Perry v. Commissioner
    IRCCourt RulingsSep 14, 2016
    CMS T.C. Memo. 2016-172 UNITED STATES TAX COURT BONITA L. PERRY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 28661-14. Filed September 14, 2016. Bonita L. Perry, for herself. Kristina L. Rico, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MORRISON, Judge: The respondent (referred to …
  6. T.C. Memo. 1997-363 — Albert R. Cujas, Jr. & Susan W. Cujas v. Commissioner
    IRCCourt RulingsAug 6, 1997
    …Additions To Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) - 2 - 1992 $13,005 $3,251 $457 1993 5,172 1,293 217 Susan W. Cujas Additions To Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1992 $4,528 $1,132 $127 1993 5,172 1,293 217 All section references are to the Internal Revenue Code in effect for the years in i…