T.C. Summary Opinion 2007-73 UNITED STATES TAX COURT ROBERT H. GOODE, JR. AND LOCKIE L. GOODE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9978-05S, 4802-06S. Filed May 15, 2007. Peter A. Lowy, for petitioners. Thomas L. Fenner, for respondent. JACOBS, Judge: These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petitions were filed. Pursuant to section 7463(b), the decisions to be...
T.C. Memo. 2007-40 UNITED STATES TAX COURT BERNARD A. KANSKY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9544-04, 24528-04L. Filed February 20, 2007. Bernard A. Kansky, pro se. Michael R. Fiore, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: In these consolidated cases, petitioner seeks review pursuant to sections 6320(c) and 6330(d) of respondent’s determination sustaining the filing of tax liens with respect to petitioner’s Federal income...
T.C. Memo. 2007-109 UNITED STATES TAX COURT PATRICIA B. PATERSON, ET AL.1 Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 8093-04, 8094-04, Filed April 30, 2007. 22397-04. Thomas Edward Brever, for petitioners. David W. Sorenson and Lisa R. Woods, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION KROUPA, Judge: Respondent determined deficiencies in petitioners’ Federal income taxes and fraud penalties under 1 This case is consolidated for briefing, trial and opinion...
T.C. Memo. 2007-171 UNITED STATES TAX COURT RIVER CITY RANCHES #1 LTD., JEFFRY BERGAMYER, TAX MATTERS PARTNER, RIVER CITY RANCHES #2 LTD., JEFFRY BERGAMYER, TAX MATTERS PARTNER, RIVER CITY RANCHES #3 LTD., JEFFRY BERGAMYER, TAX MATTERS PARTNER, RIVER CITY RANCHES #4 LTD., JEFFRY BERGAMYER, TAX MATTERS PARTNER, RIVER CITY RANCHES #5 LTD., JEFFRY BERGAMYER, TAX MATTERS PARTNER, RIVER CITY RANCHES #6 LTD., JEFFRY BERGAMYER, TAX MATTERS PARTNER, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL...
T.C. Memo. 2007-51 UNITED STATES TAX COURT LOAD, Inc., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent COAD, Inc., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 7287-02, 7294-02. Filed March 6, 2007. John F. Daniels III, Julio M. Zapata, and Eric J. Boyd, for petitioners. Charles B. Burnett, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SWIFT, Judge: Respondent determined deficiencies in petitioners’ Federal income taxes for their separate taxable...
T.C. Memo. 2007-325 UNITED STATES TAX COURT CARL KLEIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 7162-06L, 7163-06L. Filed October 30, 2007. Robert E. McKenzie and Kathleen M. Lach, for petitioner. Gregory J. Stull and Gorica B. Djuraskovic, for respondent. MEMORANDUM OPINION JACOBS, Judge:1 The petitions in these consolidated cases were each filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 1 These cases...
T.C. Summary Opinion 2007-148 UNITED STATES TAX COURT NORMAN P. SCHIFF, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 6781-05S, 11265-05S. Filed August 27, 2007. Norman P. Schiff, pro se. Orsolya Kun, for respondent. NIMS, Judge: These cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petitions were filed. Pursuant to section 7463(b), the decisions to be entered are not reviewable by any other court, and this...
T.C. Memo. 2007-169 UNITED STATES TAX COURT ESTATE OF SYLVIA GORE, DONOR, DECEASED, PAMELA POWELL, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent ESTATE OF SYLVIA GORE, DECEASED, PAMELA POWELL, PERSONAL REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 467-02, 468-02. Filed June 27, 2007. Paul R. Hodgson and James E. Poe, for petitioner. Elizabeth Downs, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION MARVEL,...
T.C. Summary Opinion 2007-179 UNITED STATES TAX COURT LAZAR SIMOV KOVACHEVICH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 4480-06S, 4481-06S. Filed October 24, 2007. Lazar Simov Kovachevich, pro se. Patricia A. Rieggar, for respondent. DEAN, Special Trial Judge: These consolidated cases were heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petitions were filed. Pursuant to section 7463(b), the decisions to be...
T.C. Memo. 2007-315 UNITED STATES TAX COURT STANLEY C. WOLCOTT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 4371-06, 4372-06. Filed October 18, 2007. P failed to file Federal income tax returns for 2000 and 2001 until after he was issued a notice of deficiency for those taxable years. R determined deficiencies and additions to tax pursuant to secs. 6651(a)(1) and (2) and 6654(a), I.R.C. P conceded the deficiencies. Held: P is liable for the additions to tax pursuant...
T.C. Memo. 2007-293 UNITED STATES TAX COURT ESTATE OF CHARLES A. LIPPITZ, DECEASED, MICHAEL LIPPITZ, ADMINISTRATOR AND RHITA S. LIPPITZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 35775-84, 45694-85, Filed September 25, 2007. 360-87, 37518-87, 32365-88, 27448-89. P-Wife moved to amend the petitions to assert a claim for innocent spouse relief under sec. 6015(c) and (f), I.R.C. Subsequently, P-Wife moved for summary judgment, and R conceded. P-Wife now seeks...
T.C. Memo. 2007-202 UNITED STATES TAX COURT ROBERT AND INES M. GILLESPIE, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 3405-05L, 3489-05L, Filed July 24, 2007. 3490-05L. These cases brought pursuant to sec. 6330, I.R.C., are before the Court to determine whether Ps must pay penalties pursuant to sec. 6673(a)(1), I.R.C., for instituting procedures primarily for delay, etc., and whether counsel must pay R’s excess counsel fees pursuant to sec. 6673(a)(2), I.R.C....
T.C. Memo. 2007-158 UNITED STATES TAX COURT G. KIERSTEAD FAMILY HOLDINGS TRUST, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 24183-05, 24184-05, Filed June 19, 2007. 24185-05. Anthony V. Diosdi, for petitioners. Jeremy L. McPherson, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HAINES, Judge: Petitioners in these consolidated cases are G. Kierstead Family Holdings Trust, G. Kierstead Family Trust, and Glenn E. and Carol L. Kierstead as individuals....
T.C. Summary Opinion 2007-112 UNITED STATES TAX COURT JACK DANIEL CHAVEZ, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 23941-04S, 2374-06S. Filed July 2, 2007. Paul S. Braun, for petitioner. Kathleen Schlenzig, for respondent. GOLDBERG, Special Trial Judge: These cases were consolidated and heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petitions were filed. Pursuant to section 7463(b), the decisions to be...
T.C. Memo. 2007-23 UNITED STATES TAX COURT JOHN E. HUNTER, II AND ALMA E. HUNTER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent JOHN ERWIN HUNTER, II, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 23649-04, 14984-05L. Filed February 5, 2007. John E. Hunter, II, and Alma E. Hunter, pro sese in docket No. 23649-04. John Erwin Hunter, II, pro se in docket No. 14984-05L. A. Gary Begun, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge:...
T.C. Summary Opinion 2007-117 UNITED STATES TAX COURT PAULA L. WILSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent MICHAEL EDWARD RYAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 22721-05S, 22747-05S. Filed July 11, 2007. Scott P. Hendricks, for petitioners. Catherine S. Tyson, for respondent. FOLEY, Judge: This case was heard pursuant to section 74631 of the Internal Revenue Code in effect when the petitions were 1 Unless otherwise indicated, all...
