152 T.C. No. 1 UNITED STATES TAX COURT RENEE VENTO, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 992-06, 993-06, Filed February 4, 2019. 1168-06. Following our previous Opinion holding that Ps are not entitled to foreign tax credits under I.R.C. sec. 901 for certain amounts paid to the U.S. Virgin Islands, the parties were ordered to submit computa- tions for entry of decision under Tax Court Rule 155. In their compu- tations Ps took the position that the...
T.C. Memo. 2019-154 UNITED STATES TAX COURT LOWELL G. DEN BESTEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9768-15. Filed November 25, 2019. Lowell G. Den Besten, pro se. Dennis Richard Onnen, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PARIS, Judge: Respondent determined deficiencies in petitioner’s Federal income tax of $51,360, $46,200, $66,692, $41,228, and $25,214 and accuracy- related penalties under section 6662(a)1 of $10,272, $9,240, $13,338.40,...
153 T.C. No. 8 UNITED STATES TAX COURT RICHARD E. LACEY, II, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9761-16W. Filed November 25, 2019. P filed a whistleblower claim with the Whistleblower Office (“WBO”) of the Internal Revenue Service (“IRS”). The claim contained a one-page narrative that alleged that amounts spent by the target taxpayer, purportedly to remediate an environmental disaster, were in fact spent not to remediate environmental damage but rather to...
T.C. Summary Opinion 2019-3 UNITED STATES TAX COURT ROSEMARY MCDOWELL AND ADRIC MCDOWELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 973-17S. Filed March 4, 2019. Rosemary McDowell and Adric McDowell, pro sese. Jacob Russin, for respondent. SUMMARY OPINION PANUTHOS, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be...
T.C. Memo. 2019-110 UNITED STATES TAX COURT DUANE LEE CHAPMAN AND ALICE E. SMITH, DECEASED, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9242-14. Filed August 29, 2019. Steven Ray Mather and Lydia B. Turanchik, for petitioners. S. Penina Shadrooz and Catherine G. Chang, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION ASHFORD, Judge: By statutory notice of deficiency dated November 29, 2012, the Internal Revenue Service (IRS or respondent) determined...
T.C. Memo. 2019-44 UNITED STATES TAX COURT TIMOTHY TODD FISHER AND CHRISTINA FISHER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9201-17. Filed April 30, 2019. Timothy Todd Fisher and Christina Fisher, pro sese. A. Gary Begun, Randall Childs, and Mark J. Tober, for respondent. MEMORANDUM OPINION VASQUEZ, Judge: This case is before the Court on respondent’s motion for summary judgment.1 The issue for decision is whether petitioners’ tax liability 1 Unless otherwise...
T.C. Memo. 2019-140 UNITED STATES TAX COURT PLANO HOLDING LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9169-17. Filed October 16, 2019. Donald A. Barnes, for petitioner. Thomas F. Harriman, Naseem Jehan Khan, and Michelle E. Marcove, for respondent. MEMORANDUM OPINION URDA, Judge: The Ontario Teachers’ Pension Plan Board (OTPP) is one of Canada’s largest institutional investors. In 2012 it caught whiff of a chance to acquire Plano Molding Co. (Plano), an Illinois...
T.C. Memo. 2019-157 UNITED STATES TAX COURT MARTIN WASHINGTON BROWN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8999-17L. Filed December 9, 2019. Martin Washington Brown, pro se. Shari A. Salu, Ryan Z. Sarazin, and Bartholomew Cirenza, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge: In this collection due process (CDP) case petitioner seeks review pursuant to sections 6320(c) and 6330(d)(1)1 of the determination by the Internal Revenue Service (...
T.C. Summary Opinion 2019-11 UNITED STATES TAX COURT DONALD BURDEN AND MARY TORRES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8967-16S. Filed June 24, 2019. Herald J. A. Alexander, for petitioners. David Delduco and Huiwen A. Xi, for respondent. SUMMARY OPINION HALPERN, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed. 1 Unless otherwise indicated, all section references are to...
152 T.C. No. 17 UNITED STATES TAX COURT ATLANTIC PACIFIC MANAGEMENT GROUP, LLC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8412-18. Filed June 20, 2019. In this collection due process (CDP) case R assessed penalties under I.R.C. sec. 6698(a) against P for late partnership information return filings for 2014 and 2015 and a penalty under I.R.C. sec. 6038(b) for failing to file an information return with respect to certain foreign corporations and partnerships for 2014....
T.C. Summary Opinion 2019-17 UNITED STATES TAX COURT JUN WU, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8009-16S. Filed July 25, 2019. Jun Wu, pro se. Sandeep Singh, for respondent. SUMMARY OPINION CARLUZZO, Chief Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code (Code) in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be entered is 1 Unless otherwise indicated, section...
T.C. Summary Opinion 2019-8 UNITED STATES TAX COURT JOEL H. ARSEO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7862-18S. Filed May 2, 2019. Joel H. Arseo, pro se. Gretchen W. Altenburger, for respondent. SUMMARY OPINION GERBER, Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all...
T.C. Memo. 2019-55 UNITED STATES TAX COURT CONSTANCE H. BRILEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7782-17. Filed May 22, 2019. Charles I. Cate, for petitioner. Shari A. Salu, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION JACOBS, Judge: This matter is before us with respect to respondent’s denial of petitioner’s request for spousal relief from joint and several liability under section 60151 for 2004 and 2005 (years involved). 1 Unless otherwise...
T.C. Memo. 2019-12 UNITED STATES TAX COURT LAURA DENISE CONTRERAS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7713-16. Filed February 26, 2019. Bruce A. McGovern, Jeffery A. Gold, and Heidi A. Weelborg (student), for petitioner. Susan M. Fenner and Christina D. Sullivan, for respondent. -2- [*2] MEMORANDUM FINDINGS OF FACT AND OPINION PARIS, Judge: Pursuant to section 6015(e)(1)1 petitioner seeks review of respondent’s determination that she is not entitled to...
152 T.C. No. 10 UNITED STATES TAX COURT WHISTLEBLOWER 769-16W, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 769-16W. Filed April 11, 2019. R’s Whistleblower Office denied P’s whistleblower award claim under I.R.C. sec. 7623(b). After P filed a petition challenging R’s decision, R filed a motion to remand this case to the Whistleblower Office for further consideration. P objects to the granting of R’s motion. Held: In appropriate circumstances this Court may remand a...
T.C. Memo. 2019-129 UNITED STATES TAX COURT COLEMAN MOORE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7390-16L. Filed September 30, 2019. Carlos S. Lopez, for petitioner. Adam B. Landy, Nancy M. Gilmore, and Thomas R. Mackinson, for respondent. MEMORANDUM OPINION GOEKE, Judge: Petitioner challenges respondent’s attempt to collect by levy unpaid trust fund recovery penalties (TFRP) for which petitioner is a responsible officer. These matters turn on whether the...
T.C. Summary Opinion 2019-21 UNITED STATES TAX COURT GERARD J. MCENROE AND REGINA MCENROE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7381-18S. Filed August 20, 2019. Gerard J. McEnroe and Regina McEnroe, pro sese. Monica E. Koch, for respondent. SUMMARY OPINION GUY, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the decision to be...
T.C. Memo. 2019-77 UNITED STATES TAX COURT SHELDON SAPOZNIK AND MELISSA MCCROSSEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Docket No. 7335-17. Filed June 18, 2019. Norman D. McKellar, for petitioners. William Benjamin McClendon and William Walter Kiessling, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION NEGA, Judge: By notice of deficiency dated January 10, 2016,1 respondent determined deficiencies in the Federal income tax of petitioners and accuracy- 1 The...
T.C. Memo. 2019-107 UNITED STATES TAX COURT TARYN L. DODD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7316-17L. Filed August 22, 2019. Taryn L. Dodd, pro se. Rachel L. Rollins, Jeffrey E. Gold, Deborah Aloof, and Jacob Russin, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case, petitioner seeks review of a determination by the Internal Revenue Service (IRS or respond- ent) to uphold collection action. The IRS has moved for...
T.C. Memo. 2019-82 UNITED STATES TAX COURT SAMUEL WEGBREIT AND ELIZABETH J. WEGBREIT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent THE SAMUEL WEGBREIT TRUST FUND, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 7109-13, 15305-13. Filed July 8, 2019. John E. Rogers, for petitioners. Lauren N. May, David A. Lee, Angela B. Reynolds, Michelle E. Marcove, Naseem Jehan Khan, Thomas F. Harriman, and Tess Deliefde, for respondent. MEMORANDUM FINDINGS OF FACT AND...
