Documents

UNITED STATES TAX COURT

Agency decision · Agency decision

Due to a lack of available treatment for his ongoing medical problems, petitioner departed Alaska on December 24 and returned to Nevada on or about December 27, 1991. … Memo. 1994-399; sec. 1.183-2(a), Income Tax Regs.

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 24 B.T.A. 828, 829 (1931); Neeman v. Commissioner, 13 T.C. 397, 399 (1949), affd. 200 F.2d 560 (2d Cir. 1952).

UNITED STATES TAX COURT

Agency decision · Agency decision

Betsy charged the $399 cost of this ticket on her Markette American Express credit card. … Accordingly, that $399 is not properly an expense of the Miami trips paid for by check Nos.

UNITED STATES TAX COURT

Agency decision · Agency decision

On July 24, 2002, respondent disallowed the refund claim that was filed by Mr. Walker for 1997 and sent to petitioner a notice of deficiency for 1997 and 1998. … Commissioner, 13 T.C. at 399; Estate of Ballantyne v. Commissioner, T.C. Memo. 2002-160; Bonner v. Commissioner, T.C. Memo. 1979-435.

UNITED STATES TAX COURT

Agency decision · Agency decision

Rul. 74-611, 1974-2 C.B. 399. 2. Shelley Since the overpayment was attributable entirely to taxes withheld from Shelley's income, she alone has any interest in the refund of the overpayment. … --For purposes of section 6511 or 6512-(1) Any tax actually deducted and withheld at the source during any calendar year under chapter 24 shall, in respect of the recipient of the income, be deemed to

UNITED STATES TAX COURT

Agency decision · Agency decision

In a final determination dated August 24, 2014, respondent denied petitioner's request for relief from joint and several liability for tax years 2010 and 2011. … Proc. 2013-34, sec. 4, 2013-43 I.R.B. 397, 399-403. I. Rev. Proc. 2013-34: Equitable Factors Rev.

United States Tax Court

Agency decision · Agency decision

Served 10/08/24 2 Background Petitioner and Charles Bolgiani married in 2007. For part of their marriage, petitioner and Mr. Bolgiani lived together in a home given to her in 2011. … Proc. 2013-34, § 4.01, 2013-43 I.R.B. at 399–400, sets forth seven threshold conditions that must be satisfied before the Commissioner may consider granting relief.

United States Tax Court

Agency decision · Agency decision

Howbert, 231 U.S. 399, 415 (1913))). Petitioners also argue that wage income is taxable only if it is related to certain activities and that respondent does not have personal knowledge of Mrs. … Memo. 2015-104, at *24, aff’d, 649 F. App’x 299 (4th Cir. 2016). As we have found, petitioners’ arguments are frivolous and have been consistently rejected by courts.

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 437 F.3d 399, 405 (3d Cir. 2006) (discussing a similarly illogical result where a taxpayer has not made any underlying investment in an asset), affg. T.C. Memo. 2004-216. … Instead, their rights in the credits, - 24 - although achieved because of the property, arose on account of the grant from the State. Unlike the easement granted in Fasken v.

UNITED STATES TAX COURT

Agency decision · Agency decision

See 4 sec. 4.01, 2013-43 I.R.B. at 399-400. … - 24 [*24] Respondent concedes that petitioner satisfies the economic hardship requirement. Intervenor disagrees, arguing that petitioner has not suffered from any financial hardship.

UNITED STATES TAX COURT

Agency decision · Agency decision

Rul. 74-611, 1974-2 C.B. 399. 2. Shelley Since the overpayment was attributable entirely to taxes withheld from Shelley's income, she alone has any interest in the refund of the overpayment. … --For purposes of section 6511 or 6512-(1) Any tax actually deducted and withheld at the source during any calendar year under chapter 24 shall, in respect of the recipient of the income, be deemed to

T.C. Summary Opinion 2016-2

Agency decision · Agency decision

Elbe divorced on October 24, 2012. The divorce decree, entered on December 20, 2012, stated that Mr. … On April 24, 2014, the IRS Appeals Office reversed CCISO's preliminary determination and issued a final notice of determination to Mr.

T.C. Summary Opinion 2016-75

Agency decision · Agency decision

- 12 section 6015(e)(1)(A)(i)(II) and in the absence of other evidence, March 24, 2014, the date on which respondent received petitioner's request, is the operative second date. … Proc. 2013-34, sec. 4.01(3), 2013-43 I.R.B. 397, 399.

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 13 T.C. 397, 399 (1949), affd. 200 F.2d 560 (2d Cir. 1952); Humbert v. Commissioner, 24 B.T.A. 828, 829 (1931).

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 13 T.C. 397, 399 (1949), affd. 200 F.2d 560 (2d Cir. 1952); Humbert v. Commissioner, 24 B.T.A. 828, 829 (1931).

T.C. Summary Opinion 2003-108

Agency decision · Agency decision

Commissioner, 114 T.C. 399 (2000), affd. 259 F.3d 881 (7th Cir. 2001). … R.R., supra at 24-25, and the provisions held constitutional therein (for example, upholding the constitutionality of the corporate income tax, and observing that “the due process clause of the 5th Amendment

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 399 F.2d at 606; Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. 1142, 1156 (1980). In Elliotts, Inc. v. … Commissioner, 399 F.2d at 606; see also Estate of Wallace v. Commissioner, 95 T.C. at 553-554. B.

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 13 T.C. 397, 399 (1949), affd. 200 F.2d 560 (2d Cir. 1952); Humbert v. Commissioner, 24 B.T.A. 828, 829 (1931).

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 13 T.C. 397, 399 (1949), affd. 200 F.2d 560 (2d Cir. 1952); Humbert v. Commissioner, 24 B.T.A. 828, 829 (1931).

UNITED STATES TAX COURT

Agency decision · Agency decision

Hazen, 451 A.2d 398,.399 (N.H. 1982) (permitting divorce to take effect, notwithstanding the wife's death during the pendency of the husband's appeal related to property rights); Stritch v. … Jan. 24, 2008)] that fees incurred after the date of the final divorce decree could not have been part of the property settlement,' and, therefore, were required to be reviewed under Gosselin".).