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85 documents · 0.23sAllIRCERISAPBGCJoint Board
  1. 29 T.C. 175 — Park Sherman Co. v. United States
    IRCCourt RulingsOct 30, 1957related by meaning
    no evidence whatever to refute respondent’s determination. For failure of proof, we necessarily sustain respondent’s determination as to Bloom-ington. Because of the possibility of minor adjustments indicated by the stipulation of facts filed herein, Decisions will be entered under Bule 50. Sec. 403 (a). For the purpos…
  2. T.C. Memo. 2019-1 — Robert Wesley v. Commissioner
    IRCCourt RulingsMar 14, 2019related by meaning
    ho conducted petitioner's CDP hearing, a USPS document relating to the notice of deficiency for 2012, and a copy of this Court's order and decision in Wesley v. Commissioner, docket No. 6560-14L. At trial petitioner offered and we admitted into evidence a screen shot of information he had downloaded from the USPS track…
  3. 144 T.C. No. 9 — Ralim S. El v. Commissioner
    IRCCourt RulingsMar 12, 2015related by meaning
    nd.8 SSeveral recent cases cite Bunney v. Commissioner, 114 T.C. 259, 265 (2000) (citing Matthews v. Commissioner, 92 T.C. 351, 361-362 (1989), aff'd, 907 F.2d 1173 (D.C. Cir. 1990)), where we held that the taxpayer "has the burden of proving his entitlement to any of * * * [the sec. 72(t)(2)(A)] exceptions." Sg g, Hyd…
  4. Notice 2026-33 — This notice provides guidance with respect to section 334 of Division T of the Consolidated Appropriations Act, 2023, Pub. L. 117-328, 136 Stat. 3559 (2022), k…
    IRCNoticesJun 8, 2026related by meaning
    is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Legislation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Sub…
  5. I.R.C. § 6701(c) — Penalties for aiding and abetting understatement of tax liability
    IRCCode / StatuteJan 4, 1995related by meaning
    (c) (c) Activities of subordinates (c)(1) (1) In general For purposes of subsection (a), the term "procures" includes— (c)(1)(A) (A) ordering (or otherwise causing) a subordinate to do an act, and (c)(1)(B) (B) knowing of, and not attempting to prevent, participation by a subordinate in an act. (c)(2) (2) Subordinate F…