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81. Notice 2026-32 — This notice provides that a broker-dealer that carries customer accounts and receives or holds funds or securities for those customers may, in lieu of demonstr…
    IRCNoticesJun 15, 2026
    …nts (HRAs) provided under § 54.9831-1(c)(3)(viii) of the Pension Excise Tax Regulations. 26 CFR 601.602: Tax forms and instructions. (Also: Part I, §§ 1, 223, Part III § 54.9831-1) EMPLOYEE PLANS Notice 2026-32, page 1578. This notice provides that a broker-dealer that carries customer accounts and receives or holds fu…
82. T.C. Memo. 1997-487 — Richard Walter Drake v. Commissioner
    IRCCourt RulingsOct 28, 1997
    …enses as follows: Advertising $340 Auto and travel 1,710 Cleaning and maintenance 2,617 Insurance 2,602 Legal and other professional fees 127 Mortgage interest 27,263 Repairs 4,896 Supplies 78 Taxes 13,780 Utilities 1,721 Total $55,134 Thus petitioner claimed a loss of $33,139 from rental real estate. Petitioner claime…
83. 77 T.C. 1169 — Reiff v. Commissioner
    IRCCourt RulingsNov 30, 1981related by meaning
    general tax credit (sec. 42), which apparently was taken into account by respondent in his assertion of an increased deficiency and additions to tax. Respondent concedes that, if the 32-page document filed by petitioners with respondent for 1977 constitutes an income tax return for purposes of sec. 6651(a), then the r…
84. T.C. Summary Opinion 2019-26 — Pascal Nsame & Lamiaa Msalka v. Commissioner
    IRCCourt RulingsSep 23, 2019
    …ness. See Quock Ting v. United States, 140 U.S. 417, 420-421 (1891); Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), af[g 41 T.C. 593 (1964); Pinder v. United States, 330 F.2d 119, 124125 (5th Cir. 1964); Concord Consumers Hous. Coop. v. Commissioner, 89 T.C. 105, 124 n.21 (1987). Witness testimony could almos…
85. T.C. Memo. 2007-306 — David Brian Nolan v. Commissioner
    IRCCourt RulingsOct 9, 2007related by meaning
    ers . In response to our leniency, petitioner once again ignored our Rules and our order . -5On account of petitioner 's repeated failure to obey ou r Rules and orders, we considered dismissing this case as a sanction pursuant to Rule 123(b) . See Stringer v . Commissioner , 84 T .C . 693, 704-705 (1985), affd . withou…
86. T.C. Memo. 2013-171 — Sean Richards v. Commissioner
    IRCCourt RulingsJul 24, 2013
    …efundable education credit of $1,500. On his 2009 return, Mr. Richards claimed an overpayment of $7,602 that he requested be refunded to him. [*4] Administrative proceedings When the IRS processed Mr. Richards's return, it corrected mathematical errors, assessed the resulting tax (greater than Mr. Richards had reported…
87. 99 T.C. 622; 99 T.C. No. 32 — Burton v. Commissioner
    IRCCourt RulingsDec 17, 1992related by meaning
    Hamblen, Chief Judge: Respondent determined deficiencies in petitioners’ 1985 and 1986 Federal income tax in the respective amounts of $74,904.30 and $40,585.81. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable years at issue, and Rule references are to the Tax C…
88. T.C. Summary Opinion 2009-137 — Richard & Brenda Lee Liu v. Commissioner
    IRCCourt RulingsSep 3, 2009
    …ent . determined a $3,010 deficiency in petitioners' 2005 Federal income tax and also determined a $602 accuracyrelated penalty . After a concession by petitioners,2 the issues for decision are : (1) Whether petitioners are liable for the 1 .0-percent penalty pursuant to section 72(q) on a premature distribution from a…
89. 101 T.C. 215; 101 T.C. No. 15 — Clark v. Comm'r
    IRCCourt RulingsSep 14, 1993related by meaning
    nternal Revenue Code of 1986 (as amended by subsection (a) [of this Act]) that the distribution be received after attaining age 591/2 shall not apply. (C) Lump Sum Distributions to Which Paragraph Applies. — This paragraph shall apply to any lump sum distribution if— (i) such lump sum distribution is received by an ind…
90. T.C. Memo. 2006-47 — Diep N. Hoang v. Commissioner
    IRCCourt RulingsMar 20, 2006
    …s not required to accept petitioner's unsubstantiated testimony. See Wood v. Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C. 593 (1964). The Court need not accept at face value a witness's testimony that is self-interested or otherwise questionable. See Archer v. Commissioner, 227 F.2d 270, 273 (5th Cir.…
91. 112 T.C. No. 6 — Gideon L. & Corazon P. Medina v. Commissioner
    IRCCourt RulingsFeb 22, 1999related by meaning
    lating to petitioners' loan, 10.5 percent is the fair market interest rate. V. Addition to Tax Each disqualified person liable for section 4975 excise taxes with respect to a prohibited transaction is required to file Form 5330 for each taxable year, or portion thereof, in the taxable period. Sec. 6011; sec. 54.6011-1(…