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. |
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Results 1-5 of 100
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United States. Tax Court. OPINION MARVEL , Judge : Respondent determined a deficiency in petitioners ' Federal income tax ... respondent's deter- mination . After concessions , 2 the issues for decision are : ( 1 ) Whether petitioners may ...
United States. Tax Court. OPINION MARVEL , Judge : Respondent determined a deficiency in petitioners ' Federal income tax ... respondent's deter- mination . After concessions , 2 the issues for decision are : ( 1 ) Whether petitioners may ...
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... respondent's determination in the notice of deficiency is arbitrary , exces- sive , and without foundation , respondent's determination is not entitled to any presumption of correctness and that respondent bears the burden of proof . 10 ...
... respondent's determination in the notice of deficiency is arbitrary , exces- sive , and without foundation , respondent's determination is not entitled to any presumption of correctness and that respondent bears the burden of proof . 10 ...
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... Respondent contends that petitioners did not sell property they had owned and used as their principal residence for ... Respondent's argument interprets the term " property " to mean , or at least include , a dwelling that was owned and ...
... Respondent contends that petitioners did not sell property they had owned and used as their principal residence for ... Respondent's argument interprets the term " property " to mean , or at least include , a dwelling that was owned and ...
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... respondent's burden of producing evidence that the section 6651 ( a ) ( 1 ) addition to tax applies . Petitioners did not intro- duce any evidence to prove that they had reasonable cause for their failure to file their 2000 return ...
... respondent's burden of producing evidence that the section 6651 ( a ) ( 1 ) addition to tax applies . Petitioners did not intro- duce any evidence to prove that they had reasonable cause for their failure to file their 2000 return ...
Page 45
... respondent has met his burden of production under section 7491 ( c ) ; and in order to avoid the section 6651 ( a ) ( 1 ) ... respondent's determination and hold petitioners liable for the addition to tax pursuant to section ( 26 ) 45 ...
... respondent has met his burden of production under section 7491 ( c ) ; and in order to avoid the section 6651 ( a ) ( 1 ) ... respondent's determination and hold petitioners liable for the addition to tax pursuant to section ( 26 ) 45 ...
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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