Karlsson v. Commissioner, Tax Ct. Dkt. Nos. 16542-86; 45989-86 (1997)

T.C. Memo. 1997-432 UNITED STATES TAX COURT PELLE KARLSSON AND EVELYN T. KARLSSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 16542-86, 45989-86. Filed September 23, 1997. Mark D. Pastor and Robert T. Leonard, for petitioners. Elizabeth Girafalco Chirich, Susan K. Greene, Karen M. Tate, and Marion S. Friedman, for respondent. MEMORANDUM OPINION SWIFT, Judge: This matter is before us on our order to show cause why resolution of the issues in these consolidated cases...

Gordon v. Commissioner, Tax Ct. Dkt. No. 9887-95; 9900-95 (1997)

T.C. Memo. 1997-422 UNITED STATES TAX COURT BEVERLY GORDON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent RONALD GORDON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 9887-95, 9900-95. Filed September 22, 1997. Vincent R. Barrella, for petitioner in docket No. 9887-95. Ronald Gordon, pro se in docket No. 9900-95. Rajiv Madan and Anthony J. Kim, for respondent. SUPPLEMENTAL MEMORANDUM OPINION CHIECHI, Judge: This case is before us on the motion filed * This...

Theisen v. Commissioner, Tax Ct. Dkt. No. 9759-96 (1997)

T.C. Memo. 1997-539 UNITED STATES TAX COURT KENNETH C. & BECKY J. THEISEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9759-96. Filed December 8, 1997. Rory Alan Boatright, for petitioner. Franklin R. Hise, for respondent. MEMORANDUM OPINION PAJAK, Special Trial Judge: This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references...

Harold Levinson Assocs. v. Commissioner, Tax Ct. Dkt. No. 9575-95 (1997)

T.C. Memo. 1997-536 UNITED STATES TAX COURT HAROLD LEVINSON ASSOCIATES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9575-95. Filed December 3, 1997. Richard M. Gabor, for petitioner. Gary W. Bornholdt, for respondent. MEMORANDUM OPINION RAUM, Judge: The Commissioner determined deficiencies in petitioner's Federal income taxes for the taxable years ending January 31, 1990, and January 31, 1991, in the amounts of $179,860 and $1,349, respectively. The remaining...

Uslu v. Commissioner, Tax Ct. Dkt. No. 9317-96 (1997)

T.C. Memo. 1997-551 UNITED STATES TAX COURT SAFFET AND ANA USLU, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9317-96. Filed December 16, 1997. Saffet and Ana Uslu, pro se. Timothy F. Salel, for respondent. MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. Respondent determined a deficiency of $2,869 in petitioners' Federal income tax for 1992. 1 Unless otherwise indicated, section...

Campbell v. Commissioner, Tax Ct. Dkt. No. 9244-95 (1997)

T.C. Memo. 1997-502 UNITED STATES TAX COURT JOSEPH BALDWIN CAMPBELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9244-95. Filed November 6, 1997. Lawrence H. Crosby, for petitioner. Jonathan P. Decatorsmith, for respondent. MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year at issue....

Williams v. Commissioner, Tax Ct. Dkt. No. 9143-96 (1997)

T.C. Memo. 1997-541 UNITED STATES TAX COURT PATRICIA WILLIAMS, a.k.a. PATRICIA RICHARDSON, a.k.a. TISH MARTINSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9143-96. Filed December 9, 1997. Barry L. Guterman, for petitioner. Edwin A. Herrera and Linas N. Udrys, for respondent. MEMORANDUM OPINION JACOBS, Judge: This matter is before the Court on petitioner's motion for award of litigation and administrative costs pursuant to section 74301 and Rule 231. 1 References to...

Variety Club Tent No. 6 Charities v. Commissioner, Tax Ct. Dkt. No. 9045-90 (1997)

T.C. Memo. 1997-575 UNITED STATES TAX COURT VARIETY CLUB TENT NO. 6 CHARITIES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9045-90. Filed December 31, 1997. Petitioner was incorporated in 1970 to raise funds for tax-exempt charitable organizations, primarily those benefiting underprivileged children. Petitioner received a favorable ruling letter in 1971. Much of petitioner’s fundraising consisted of operating bingo games. Petitioner’s treasurer (Z) and a member (...

Haderlie v. Commissioner, Tax Ct. Dkt. No. 8856-96 (1997)

T.C. Memo. 1997-525 UNITED STATES TAX COURT VERL W. AND FRANCES M. HADERLIE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8856-96. Filed November 19, 1997. Verl W. and Frances M. Haderlie, pro sese. Michael W. Lloyd, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined a $10,049 deficiency in petitioners' 1991 income tax that is attributable to one adjustment.1 That adjustment pertains to a scheme where 1 An automatic...

A.C. Green Elec. Contrs. v. Commissioner, Tax Ct. Dkt. No. 8794-95 (1997)

T.C. Memo. 1997-556 UNITED STATES TAX COURT A.C. GREEN ELECTRICAL CONTRACTORS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8794-95. Filed December 22, 1997. Bruce H. Guttman, for petitioner. Peter J. Gavagan, for respondent. MEMORANDUM OPINION SWIFT, Judge: Respondent determined deficiencies in and additions to petitioner's Federal income and excise taxes for petitioner’s taxable years ending September 30, 1987, 1988, 1989, and 1990, as follows:  - 2 - Taxable...

Thomason v. Commissioner, Tax Ct. Dkt. No. 8746-95 (1997)

T.C. Memo. 1997-480 UNITED STATES TAX COURT HARRY E. THOMASON AND ESTATE OF HATTIE D. THOMASON, DECEASED, MARY T. CRIST, PERSONAL REPRESENTATIVE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8746-95. Filed October 22, 1997. John R. Foley, for petitioners. Leslie H. Finlow, for respondent. MEMORANDUM OPINION COUVILLION, Special Trial Judge: This case was heard 1 pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. 1 Unless otherwise indicated, section references...

Brewer v. Commissioner, Tax Ct. Dkt. No. 8612-96 (1997)

T.C. Memo. 1997-542 UNITED STATES TAX COURT CHERYL DENESE BREWER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8612-96. Filed December 9, 1997. Cheryl Denese Brewer, pro se. Jason M. Silver, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION JACOBS, Judge: Respondent determined a $47,047 deficiency in petitioner's 1992 Federal income tax. The issues for decision are: (1) Whether petitioner is entitled to exclude from gross income amounts received in settlement of a...

Estate of Letts v. Commissioner, Tax Ct. Dkt. No. 8539-95 (1997)

Estate of Letts v. Commissioner, Tax Ct. Dkt. No. 8539-95 (1997)

Estate of Letts v. Commissioner, Tax Ct. Dkt. No. 8539-95 (1997)

Estate of Letts v. Commissioner, Tax Ct. Dkt. No. 8539-95 (1997)

Restore, Inc. v. Commissioner, Tax Ct. Dkt. No. 8508-96 (1997)

T.C. Memo. 1997-571 UNITED STATES TAX COURT RESTORE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8508-96. Filed December 29, 1997. Glen A. Stankee, for petitioner. Sergio Garcia-Pages, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION RUWE, Judge: Respondent determined deficiencies in petitioner's Federal income taxes and accuracy-related penalties as follows: Accuracy-related Penalty Year Deficiency Sec. 6662(a) 1991 $81,451 $16,290 1992 714,424 142,885...

Paleveda v. Commissioner, Tax Ct. Dkt. No. 840-96 (1997)

T.C. Memo. 1997-416 UNITED STATES TAX COURT NICHOLAS A. AND MARJORIE E. PALEVEDA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 840-96. Filed September 18, 1997. Nicholas A. Paleveda, for petitioners. Clinton M. Fried, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined deficiencies in petitioners' Federal income tax and additions to tax and accuracy-related penalties for the taxable years 1990 and 1991 as follows: Additions...

Frami v. Commissioner, Tax Ct. Dkt. No. 8333-96 (1997)

T.C. Memo. 1997-509 UNITED STATES TAX COURT EDWARD J. FRAMI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8333-96. Filed November 12, 1997. Edward J. Frami, pro se. James E. Schacht, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GERBER, Judge: Respondent determined income tax deficiencies in the amounts of $11,619 and $12,195 for petitioner's 1993 and 1994 taxable years, respectively. Respondent also determined that petitioner's 1993 and 1994 income tax...

Estate of Edwards v. Commissioner, Tax Ct. Dkt. No. 8214-93 (1997)

T.C. Memo. 1997-443 UNITED STATES TAX COURT ESTATE OF ARTHUR C. EDWARDS, DECEASED, KENNETH EDWARDS, EDWARD EDWARDS AND JAMES EDWARDS, AS TRUSTEES OF THE ARTHUR C. EDWARDS SETTLEMENT TRUST, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8214-93. Filed September 29, 1997. Owen G. Fiore and Glenn M. Alperstein, for petitioner. Debra Lynn Reale and S. Katy Lin, for respondent. MEMORANDUM OPINION FAY, Judge: This case is before us on petitioner's...

Kroposki v. Commissioner, Tax Ct. Dkt. No. 8056-96 (1997)

T.C. Memo. 1997-563 UNITED STATES TAX COURT MICHAEL G. KROPOSKI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8056-96. Filed December 23, 1997. Held: P failed to prove that any portion of a payment he received from his former employer after being laid off constitutes damages excludable under sec. 104(a)(2), I.R.C. Michael G. Kroposki, pro se. Michael P. Breton, for respondent.  - 2 - MEMORANDUM OPINION HALPERN, Judge: Respondent determined a deficiency of $30,993 in...

Alumax Inc. v. Commissioner, Tax Ct. Dkt. No. 7779-95 (1997)

Alumax Inc. v. Commissioner, Tax Ct. Dkt. No. 7779-95 (1997)