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Agency decision · Agency decision
Filed February 24, 2011. Anietra Y. Hamper, pro se. Anita A. Gill, for respondent. … inherently personal that they simply cannot qualify for section 162 treatment irrespective of the role played by such expenditures in the overall scheme of the taxpayers' trade or business")", affd. 454 F.2d 399
United States Tax CourtAgency decision · Agency decision
Filed September 24, 2019. Alfred Q. Campbell III, pro se. Martha Jane Weber and William Walter Kiessling, for respondent. … SERVED Sep 24 2019 -2[*2] Service (IRS or respondent) to uphold the issuance of a notice of intent to levy.
United States Tax CourtAgency decision · Agency decision
Bank , 437 U .S . 298 , supra at 399 ; 308-313 United States ( 1978) . … Commissioner , Badaracco supra at 399 .
United States Tax CourtAgency decision · Agency decision
-9[*9] On October 24, 2017, the IRS informed petitioner that it was denying her request to abate the additions to tax for 2010 because she did not establish a sufficient reason for her failure to timely … Id. sec. 4.01, 2013-43 I.R.B. at 399. Then, if those conditions are met, the IRS will consider whether the requesting spouse can receive relief under a streamlined determination.
United States Tax CourtAgency decision · Agency decision
It employed 23 or 24 people in During 1997, Mr. Cutts resided in the main house and had a reserved parking space in back of the main house. Mr. … Ingalls, 399 F.2d 143, 145-146 (5th Cir. 1968), revg. 272 F. Supp. 10 (N.D. Ala. 1967).
United States Tax CourtAgency decision · Agency decision
Bank , 437 U .S . 298 , supra at 399 ; 308-313 United States ( 1978) . … Commissioner , Badaracco supra at 399 .
United States Tax CourtAgency decision · Agency decision
Proc. 2013-34, 2013-43 I.R.B. 397. 24 [*24] requesting spouse did not knowingly participate in the filing of a fraudulent joint return; and (g) absent certain enumerated exceptions, the tax liability … Proc. 2013-34, § 4.01(7), 2013-43 I.R.B. at 399–400.
United States Tax CourtAgency decision · Agency decision
It employed 23 or 24 people in During 1997, Mr. Cutts resided in the main house and had a reserved parking space in back of the main house. Mr. … Ingalls, 399 F.2d 143, 145-146 (5th Cir. 1968), revg. 272 F. Supp. 10 (N.D. Ala. 1967).
United States Tax CourtAgency decision · Agency decision
Memo. 2014-257, at *24. … However, petitioner has substantiated only $399 of expenses for supplies in 2011. Petitioner is entitled to a deduction for supply expenses of $399. 8.
United States Tax CourtAgency decision · Agency decision
O n November 24, 1997, respondent assessed petitioners the sectio n 6662(a) penalty in the amount of $13,858 for petitioners' 1989 taxable year . … On February 10, 1998, respondent received a check in th e amount of $10 ,399 .25 from Commonwealth, discharged the tax lien on the Berks ounty Property, and applied the $107,399 .25 to petitioners '
United States Tax CourtAgency decision · Agency decision
Filed January 24, 2017. H and W owned INC and LLC, each an S corporation. … Cocke, 399 F.2d 433, 447 (5th Cir. 1968) (describing the "general tax principle, that deductions for expenses can be taken only by the party who actually 'paid or incurred' them"); H.W. Nelson Co. v.
United States Tax CourtAgency decision · Agency decision
Rul. 69-511, 1969-2 C.B. 24; Hall & Ruckel, Inc. v. Commissioner, a Memorandum Opinion of this Court dated Dec. 7, 1942; C. Ludwig Baumann & Co. v. … Tomlinson, 399 F.2d 652 (5th Cir. 1968); Coastal Terminals, Inc. v. United States, 320 F.2d 333 (4th Cir. 1963); sec. 1.1031(a)-1(c), Income Tax Regs.; Rev. Rul. 61-119, 1961-1 C.B. 395.
United States Tax CourtAgency decision · Agency decision
Rul. 59-354, 1959-2 C.B. 24. Rev. … Commissioner, 115 T.C. 376, 399 n.22 (2000), affd. 283 F.3d 1258 (11th Cir. 2002).
United States Tax CourtAgency decision · Agency decision
Memo. 1999-24 UNITED STATES TAX COURT ILYA G. AND SOPHIA K. MARGOLIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18606-97. Filed January 29, 1999. … Commissioner, 399 F.2d 744, 748 (4th Cir. 1968), affg. T.C. Memo. 1967-67; Tokarski v. Commissioner, 87 T.C. 74, 77 (1986); Estate of Mason v.
United States Tax CourtAgency decision · Agency decision
Thompson’s bank account on June 24, 2016. Mrs. Thompson did not make any income tax payments for tax year 2016. OPINION I. … United States, 80 F.2d 394, 399 (8th Cir. 1935). A.
United States Tax CourtAgency decision · Agency decision
Tigue filed a motion to withdraw as counsel pursuant to Rule 24(c) (Mr. Tigue's motion to withdraw). In support of that motion, Mr. … Mitchell, supra at 399-404; United States v. Alt, 83 F.3d 779, 781-784 (6th Cir. 1996); Ianniello v. Commissioner, 98 T.C. 165, 176-185 (1992).
United States Tax CourtAgency decision · Agency decision
Most importantly, Fondag cement becomes electrically nonconductive in 24 hours compared to 7 or more days for brick. … Commissioner, 72 F.2d 399, 402 (2d Cir. 1934), revg. 23 B.T.A. 439 (1931). This inescapable cycle of exhaustion and restoration is repeated approximately every 3 years by every cell.
United States Tax CourtAgency decision · Agency decision
(d), respondent increased the child tax credit under sec. 24(a) by a like amount resulting in a wash as to that item … Proc. 2013-34, sec. 4.01, 2013-43 I.R.B. at 399, sets forth seven threshold conditions that must be satisfied before the Commissioner will consider a request for equitable relief under section 6015(f).
United States Tax CourtAgency decision · Agency decision
Served 05/13/24 2 [*2] respondent’s Motion for Partial Summary Judgment for 1998–2002 and 2010 in which respondent moved for summary adjudication that petitioner is (1) ineligible for relief pursuant … Proc. 2013-34, § 4.01, 2013-43 I.R.B. at 399. Section 4.02 lists circumstances in which the IRS will make a streamlined determination granting equitable relief.
United States Tax CourtAgency decision · Agency decision
Fletcher was the president and overall manager of - 24 [*24] TORCH, and Ms. Fletcher was the head nurse and was in charge of personnel and resident relations. … Commissioner, 399 F.2d at 606. III. Compensation Paid to Grace-Ann Strick Respondent contends that the compensation paid to Ms.
United States Tax Court
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