146 results for 'court:"U.S. Tax Court"'.
J. Morrison finds for the commissioner of internal revenue in due process claims because the court of appeals did not abuse its discretion in determining that the levy balanced tax collection efforts with plaintiff's claims that the process is unnecessarily intrusive.
Court: U.S. Tax Court, Judge: Morrison, Filed On: October 19, 2023, Case #: 2023-125, Categories: Tax
J. Copeland finds for the commissioner of internal revenue in tax deficiency claims brought against the estate of the late actor James Caan. The commissioner did not abuse his discretion in declining to waive the rollover period because the IRA contribution did not constitute a nontaxable rollover contribution.
Court: U.S. Tax Court, Judge: Copeland, Filed On: October 18, 2023, Case #: 161TC6, Categories: Tax
J. Lauber denies the commissioner of internal revenue summary judgment in this tax deficiency dispute because genuine issues remain in dispute as to whether the taxpayer intentionally attempted to evade paying taxes.
Court: U.S. Tax Court, Judge: Lauber, Filed On: October 17, 2023, Case #: 2023-124, Categories: Fraud, Tax
J. Nega finds for the commissioner of internal revenue in claims concerning a whistleblower award because the whistleblower office did not abuse its discretion in applying the sequestration reduction.
Court: U.S. Tax Court, Judge: Nega, Filed On: October 16, 2023, Case #: 161TC5, Categories: Tax, Whistleblowers
J. Weiler finds for the commissioner of internal revenue in due process claims concerning efforts to collect on tax liability because the settlement officer did not abuse her discretion, and genuine issues did not remain in dispute.
Court: U.S. Tax Court, Judge: Weiler, Filed On: October 10, 2023, Case #: 2023-123, Categories: Tax
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J. Carluzzo finds that the taxpayers presented inadequate substantiation for many expenses. Therefore, the taxpayers are liable for the additions to tax and that the accuracy related penalty include both their negligence and their substantial understatement of income tax for the subject year.
Court: U.S. Tax Court, Judge: Carluzzo, Filed On: October 3, 2023, Case #: 2023-30, Categories: Tax
J. Nega holds that Hyatt’s gross revenue from a travel rewards program for its customers was includible and not an accounting method nor a trading stamp method.
Court: U.S. Tax Court, Judge: Nega, Filed On: October 2, 2023, Case #: 2023-122, Categories: Tax
J. Lauber finds for the commissioner of internal revenue in collection due process claims stemming from a tax deficiency because issues are not in dispute and settlement officers had not abused their discretion in imposing the levy.
Court: U.S. Tax Court, Judge: Lauber, Filed On: September 26, 2023, Case #: 2023-119, Categories: Tax
J. Landy finds for the commissioner of internal revenue in tax liability claims because genuine issues do not remain in dispute and the settlement officer did not abuse his discretion in imposing the levy.
Court: U.S. Tax Court, Judge: Landy, Filed On: September 26, 2023, Case #: 2023-120, Categories: Tax
J. Morrison finds for the commissioner of internal revenue in this tax liability dispute because evidence indicates plaintiff failed to pay by the deadline.
Court: U.S. Tax Court, Judge: Morrison, Filed On: September 26, 2023, Case #: 2023-121, Categories: Tax
J. Foley finds for the commissioner of internal revenue concerning the computerized assessment of tax penalties because the taxpayer neither responded nor made efforts to become current on filing obligations.
Court: U.S. Tax Court, Judge: Foley, Filed On: September 14, 2023, Case #: 161-TC-3, Categories: Civil Procedure, Tax
J. Nega finds for the commissioner of internal revenue in this dispute over penalties assessed for tax deficiencies because plaintiff failed to demonstrate reasonable cause for being granted a good faith exception.
Court: U.S. Tax Court, Judge: Nega, Filed On: September 13, 2023, Case #: 2023-116, Categories: Tax
J. Holmes finds for the commissioner of internal revenue in this tax liability dispute because capitalized interest payments the owner made to the company did not constitute deductible interest payments.
Court: U.S. Tax Court, Judge: Holmes, Filed On: September 11, 2023, Case #: 2023-114, Categories: Tax
J. Urda finds for the commissioner of internal revenue in due process claims because evidence indicates the taxpayer had not complied with payment obligations and that the settlement officer justifiably sustained notice of intent to levy.
Court: U.S. Tax Court, Judge: Urda, Filed On: September 11, 2023, Case #: 2023-115, Categories: Civil Procedure, Tax
J. Greaves finds for the commissioner of internal revenue in this tax liability dispute because the taxpayers failed to "assign error" or demonstrate where the commissioner erred in determining the deficiency or attached penalties. Affirmed.
Court: U.S. Tax Court, Judge: Greaves, Filed On: September 11, 2023, Case #: 2023-28, Categories: Tax
J. Weiler finds in favor of the commissioner in this collection due process action for a tax deficiency. The office of appeals did not abuse her discretion and the evidence supports the proposed levy.
Court: U.S. Tax Court, Judge: Weiler, Filed On: August 29, 2023, Case #: 2023-27, Categories: Tax, Due Process
J. Weiler grants, in part, taxpayer’s motion to impose sanctions, it was premature to award expenses and fees.
Court: U.S. Tax Court, Judge: Weiler, Filed On: August 29, 2023, Case #: 2023-111, Categories: Sanctions, Tax, Attorney Fees
J. Foley finds the respondent’s counsel admitted that he knowingly submitted a reconstructed document, therefore the parties shall file a revised decision document. “The statutory notice of deficiency is critical to both the adjudicative and settlement processes.”
Court: U.S. Tax Court, Judge: Foley, Filed On: August 28, 2023, Case #: 2023-109, Categories: Settlements, Tax
J. Landy grants the commissioner’s motion for summary judgment, ruling there is no abuse of discretion. The individual was properly issued a notice of intent of levy.
Court: U.S. Tax Court, Judge: Landy, Filed On: August 28, 2023, Case #: 2023-110, Categories: Tax
J. Ashford finds for the commissioner of internal revenue in this tax deficiency dispute because canceled debt should have been included in the taxpayer's income.
Court: U.S. Tax Court, Judge: Ashford, Filed On: August 16, 2023, Case #: 2023-107, Categories: Tax
J. Gale finds that computation errors acknowledged by the commissioner of internal revenue should be corrected concerning deficiencies, additions to tax, and penalties due for the years at issue.
Court: U.S. Tax Court, Judge: Gale, Filed On: August 16, 2023, Case #: 2023-106, Categories: Civil Procedure, Tax
J. Goeke rules for plaintiff in this tax liability dispute by granting a $6000 rent deduction but finds that the remainder of the claimed expenses at are not allowed.
Court: U.S. Tax Court, Judge: Goeke, Filed On: August 14, 2023, Case #: 2023-105, Categories: Tax
J. Copeland grants plaintiff dismissal of claims challenging her classification as an "individual with a seriously delinquent tax debt" because doing so will not cause the commissioner of internal revenue to suffer legal prejudice.
Court: U.S. Tax Court, Judge: Copeland, Filed On: August 14, 2023, Case #: 161-TC-2, Categories: Civil Procedure, Tax
J. Nega finds for the commissioner of internal revenue in this tax liability dispute because debt relief was properly included in the company's tax return, and this gain flowed to the individual taxpayer as personal income.
Court: U.S. Tax Court, Judge: Nega, Filed On: August 10, 2023, Case #: 2023-104, Categories: Tax
J. Lauber finds for the commissioner of internal revenue in claims concerning an alleged overpayment because refunds for such are barred by statute.
Court: U.S. Tax Court, Judge: Lauber, Filed On: August 10, 2023, Case #: 2023-103, Categories: Tax
J. Lauber finds for the commissioner of internal revenue in this tax liability dispute for lack of genuine issues concerning the method with which payments had been credited to deficiencies in prior years.
Court: U.S. Tax Court, Judge: Lauber, Filed On: August 10, 2023, Case #: 2023-102, Categories: Tax
J. Ashford finds for the commissioner of internal revenue in this tax liability dispute because the wife failed to demonstrate she is entitled to relief for joint tax filing deficiencies.
Court: U.S. Tax Court, Judge: Ashford, Filed On: August 8, 2023, Case #: 2023-101, Categories: Tax
J. Weiler finds in favor of the commissioner in this collection due process action for a tax deficiency. The settlement officer did not abuse her discretion and the evidence supports the proposed levy.
Court: U.S. Tax Court, Judge: Weiler, Filed On: August 7, 2023, Case #: 2023-26, Categories: Government, Tax