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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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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".).
United States Tax CourtAgency 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".).
United States Tax CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency decision · Agency decision
Commissioner, 114 T.C. 399 (2000), affd. 259 F.3d 881 (7th Cir. 2001). … - 24 Petitioners acknowledge that the constitutionality of the alternative minimum tax was upheld in Okin v. Commissioner, T.C.
United States Tax CourtAgency decision · Agency decision
Served 11/18/24 2 Held: R lacks statutory authority to assess the penalty under I.R.C. § 6038(b)(1). … Mitchell, 303 U.S. 391, 399 (1938) (citing Oceanic Steam Navigation Co. v. Stranahan, 214 U.S. 320, 339 (1909)).
United States Tax CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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.
United States Tax CourtAgency 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
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