Reports of the United States Tax Court, Volume 135United States Tax Court, 2010 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
From inside the book
Results 1-5 of 100
Page 14
... penalty or addition to tax . Higbee v . Commissioner , supra at 446. However , the Commissioner is not required to introduce evidence regarding reasonable cause , substantial authority , or similar defenses . Id . Petitioners admit that ...
... penalty or addition to tax . Higbee v . Commissioner , supra at 446. However , the Commissioner is not required to introduce evidence regarding reasonable cause , substantial authority , or similar defenses . Id . Petitioners admit that ...
Page 27
... penalty under section 6662 ( a ) in regard to petitioners ' 2001 Federal income tax . The issues we must decide are : ( 1 ) Whether a trans- action in which Albert L. Calloway ( petitioner ) transferred 990 shares of International ...
... penalty under section 6662 ( a ) in regard to petitioners ' 2001 Federal income tax . The issues we must decide are : ( 1 ) Whether a trans- action in which Albert L. Calloway ( petitioner ) transferred 990 shares of International ...
Page 28
United States. Tax Court. petitioners are liable for an accuracy - related penalty pursu- ant to section 6662 ( a ) . FINDINGS OF FACT Some of the facts have been stipulated and are so found . The stipulated facts and the attached ...
United States. Tax Court. petitioners are liable for an accuracy - related penalty pursu- ant to section 6662 ( a ) . FINDINGS OF FACT Some of the facts have been stipulated and are so found . The stipulated facts and the attached ...
Page 29
... Penalty : 9 . 10 . 11 . Margin Requirements : Non - Callable : Non - Recourse : 12. Renewable : 990 shares of International Business Ma- chines Corporation ( IBM ) . $ 105,444.90 ( as of 8/6/01 , at $ 106.51 per share ) . 90 % of the ...
... Penalty : 9 . 10 . 11 . Margin Requirements : Non - Callable : Non - Recourse : 12. Renewable : 990 shares of International Business Ma- chines Corporation ( IBM ) . $ 105,444.90 ( as of 8/6/01 , at $ 106.51 per share ) . 90 % of the ...
Page 40
... penalty under § 6700 if the court finds that injunctive relief is appropriate to prevent the recurrence of such conduct . * * * * * * * * * To establish a violation of § 6700 warranting an injunction under § 7408 , the government must ...
... penalty under § 6700 if the court finds that injunctive relief is appropriate to prevent the recurrence of such conduct . * * * * * * * * * To establish a violation of § 6700 warranting an injunction under § 7408 , the government must ...
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Common terms and phrases
accuracy-related penalty addition to tax adjustment allowance Appeals officer apply Appointments Clause assessment Caer's estate carryback CDP hearing Chesapeake claim Commissioner Congress corporation Court of Appeals Dalton deduction Derivium determination emphasis added equitable tolling estate tax Federal income tax filed forward contract gross income IBM stock Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue jurisdiction lake house lien loan loss ment notice of deficiency Ocean Pines Office of Appeals parties partner partnership item payment percent peti petition petitioner petitioner's principal residence provides purposes pursuant PVFCS refund regulations reported respect respondent's Rule schedule section 107 shares Stat statute street light assets supra T.C. Memo Tax Court tax imposed tax liability tax shown taxable taxpayer term Texasgulf tion tioner transaction transfer trust underpayment United Virgin Islands whistleblower windfall tax WISCO withholding credits