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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.
United States Tax CourtAgency decision · Agency decision
Gordon Petitioner Petitioner $ 05/02/86 06/24/86 07/03/86 Petitioner Petitioner Mrs. Gordon 07/23/86 08/20/86 10/10/86 11/04/86 12/01/86 Mrs. Gordon Mrs. … Mitchell, 303 U.S. 391, 399-404 (1938), the United States Supreme Court stated: Congress may impose both a criminal and a civil sanction in respect to the same act or omission; for the double jeopardy
United States Tax CourtAgency 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 CourtAgency decision · Agency decision
Commissioner, 114 T.C. 399 (2000), affd. 259 F.3d 881 (7th Cir. 2001). In Guill v. … Commissioner, 114 T.C. 399, 407 (2000) (quoting Alexander v. Commissioner, 72 F.3d at 946), affd. 259 F.3d 881 (7th Cir. 2001).
United States Tax CourtAgency decision · Agency decision
Respondent then issued the Notice of Federal Tax Lien to petitioner on December 24, 2002. … Commissioner, 13 T.C. 397, 399 (1949), affd. per curiam 200 F.2d 560 (2d Cir. 1952); Casey v. Commissioner, 12 T.C. 224, 227 (1949); Bonner v. Commissioner, T.C. Memo. 1979-435; Ballenger v.
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
On June 24, 2006, petitioner married Gerald Butler. Petitioner and Mr. Butler jointly filed their 2007 Federal income tax return, which was prepared by Jules Simeon at Simeon Quick Tax Service. … Proc. 2013-34, sec. 4.01(7), 2013-43 I.R.B. at 399-400. We consider these factors in the light of the particular facts and circumstances, but we are not bound by them. See Molinet v.
United States Tax CourtAgency decision · Agency decision
Thus, the termination of the 1990 tax year on March 24, 1990, conclusively resolved, for purposes of the closing agreement, only the issues for that period. … Commissioner, 399 F.2d 744, 749 (4th Cir. 1968), affg. T.C. Memo. 1967-67, and taxpayers bear the burden of proving that such deficiencies are erroneous, Rule 142 (a) ; Parks v.
United States Tax CourtAgency decision · Agency decision
Pursuant to a June 24, 1994, court order, petitioner received from her exspouse $41,649, of which $30,000 was denominated as principal, $1,015 was denominated as attorney’s fees, and the remaining $10,634 … Commissioner, 317 U.S. 399, 403 (1943).
United States Tax CourtAgency decision · Agency decision
Served 05/22/24 2 and a section 6662 accuracy-related penalty of $1,263, for tax year 2016 (year in issue). The IRS later conceded the penalty. Petitioners do not dispute the deficiency amount. … Proc. 2013-34, § 4.01, 2013-43 I.R.B. 397, 399–400.
United States Tax CourtAgency decision · Agency decision
Finally, petitioners claim that their $824,894 payment of January 24, 2003, extinguished their tax liability . … Commi ioner, 464 U .S . 386, 399 (1984) .'
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7; Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. 1142, 1156 (1980). … Commissioner, 399 F.2d at 606; Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. at 1156. There is evidence in the record to show that Mr.
United States Tax CourtAgency decision · Agency decision
Found., Inc. re Estate of Vallery), 883 P.2d 24, 27 (In (Colo. … Clayton College, 461 P.2d 28, 30 (Colo. (1959)). 1969) (quoting 11 Restatement, Trusts 2d, sec. 399 - 16 - prevents the parties from agreeing to extinguish the conservation easements in the event
United States Tax CourtAgency decision · Agency decision
The statutory notice in this case was prepared based on the receipt books delivered to the IRS by Nanni. to petitioner on July 24, 1997. … Commissioner, 75 T.C. 389, 399 (1980).
United States Tax CourtAgency decision · Agency decision
- 6 Date 1/2/90 to 2/2/90 2/2/90 to 2/17/90 2/24/90 to 3/14/90 3/14/90 to 4/7/90 4/7/90 to 5/4/90 Total Amount $12,567 15,858 15,687 16,733 16,782 77,627 Petitioner's Rediform books for 1991 include … Petitioner was paid $1,097 and $399 in interest during 1990 and 1991, respectively.
United States Tax CourtAgency decision · Agency decision
Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398. … - 24 A.
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
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
Found., Inc. re Estate of Vallery), 883 P.2d 24, 27 (In (Colo. … Clayton College, 461 P.2d 28, 30 (Colo. (1959)). 1969) (quoting 11 Restatement, Trusts 2d, sec. 399 - 16 - prevents the parties from agreeing to extinguish the conservation easements in the event
United States Tax Court
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