Sarasota FL and Brain injury Lawyers | Alison H. Haskins -- eLawyers

Docket No. 8854-11L. Ramdas v. Comm'r (2013)

United States Tax Court Filed: Apr. 15, 2013

T.C. Memo. 2013-104 UNITED STATES TAX COURT RONALD RAMDAS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8854-11L. Filed April 15, 2013. In response to R’s notice of a proposed levy, P’s request for a collection due process (“CDP”) hearing under I.R.C. sec. 6330(d) for his 2005 income tax requested abatement of penalty and stated that he wanted a collection alternative-an offer-in-compromise (“OIC”) or an installment agreement (“IA”). At the CDP hearing before R’s Office o..

Docket No. 7586-15. Cantrell v. Comm'r (2017)

United States Tax Court Filed: Aug. 30, 2017

T.C. Memo. 2017-170 UNITED STATES TAX COURT MICHAEL L. CANTRELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7586-15. Filed August 30, 2017. Michael L. Cantrell, pro se. Edwin B. Cleverdon and Horace Crump, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: This case presents petitioner’s challenge to respondent’s fraud penalty determination under section 66631 for tax years 2001 through 2005 1 Unless otherwise indicated, all section references are to ..

Docket No. 10729-13 Spireas v. Comm'r (2016)

United States Tax Court Filed: Aug. 24, 2016

T.C. Memo. 2016-163 UNITED STATES TAX COURT SPIRIDON SPIREAS AND AMALIA KASSAPIDIS-SPIREAS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10729-13. Filed August 24, 2016. William F. Colgin, Robert R. Martinelli, and Christina K. Harper, for petitioners. Gerald A. Thorpe, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION LAUBER, Judge: The Internal Revenue Service (IRS or respondent) deter- mined, for 2007 and 2008 respectively, deficiencies in petitioners’ Federal i..

Docket No. 279-15 Canzoni v. Comm'r (2016)

United States Tax Court Filed: Aug. 25, 2016

T.C. Memo. 2016-165 UNITED STATES TAX COURT AMAS CANZONI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 279-15. Filed August 25, 2016. This opinion was withdrawn by order dated October 28, 2016, and replaced by T.C. Memo. 2018-130, filed August 15, 2018.

Docket Nos. 16300-14, 16301-14 Rutkoske v. Comm'r (2017)

United States Tax Court Filed: Aug. 07, 2017

149 T.C. No. 6 UNITED STATES TAX COURT MARK A. RUTKOSKE, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent FELIX RUTKOSKE, JR. AND KAREN E. RUTKOSKE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 16300-14, 16301-14. Filed August 7, 2017. In 2009 a limited liability company (LLC) in which Ps were members owned 355 acres of land (property) that it leased to others who used it as farmland. In 2009 LLC conveyed a conservation easement restricting the developmen..

Docket No. 24314-13S Morataya v. Comm'r (2015)

United States Tax Court Filed: Apr. 20, 2015

T.C. Summary Opinion 2015-30 UNITED STATES TAX COURT VICENTE MORATAYA AND RUTHY A. MORATAYA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24314-13S. Filed April 20, 2015. Vicente Morataya and Ruthy A. Morataya, pro sese. Miles Friedman, Kim-Khanh Nguyen, Hans F. Famularo, and Shari Wight (student), 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 petiti..

Docket No. 5145-12L. Knudsen v. Comm'r (2015)

United States Tax Court Filed: Apr. 07, 2015

T.C. Memo. 2015-69 UNITED STATES TAX COURT BARRY KNUDSEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5145-12L. Filed April 7, 2015. Barry Knudsen, pro se. Joline M. Wang, for respondent. MEMORANDUM OPINION SWIFT, Judge: This proceeding was commenced in response to a notice of determination concerning a proposed levy under section 6330 with respect to assessed Federal income tax for 2004 and 2006. Pending before the Court is respondent’s motion for summary judgment. -2..

Docket No. 17002-13 Ryther v. Comm'r (2016)

United States Tax Court Filed: Mar. 28, 2016

T.C. Memo. 2016-56 UNITED STATES TAX COURT THOMAS L. RYTHER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 17002-13. Filed March 28, 2016. Thomas L. Ryther, pro se. Sandy Hwang, for respondent. MEMORANDUM OPINION HOLMES, Judge: When his steel-fabrication business dissolved, Thomas Ryther found himself lacking income but in possession of a large quantity of scrap steel. To remedy the lack of income, Ryther sold the scrap whenever he needed to pay his bills. Ryther reported ..

Docket No. 25152-11 15 W. 17th St. LLC v. Comm'r (2016)

United States Tax Court Filed: Dec. 22, 2016

147 T.C. No. 19 UNITED STATES TAX COURT 15 WEST 17TH STREET LLC, ISAAC MISHAN, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 25152-11. Filed December 22, 2016. On its 2007 partnership return LLC claimed a charitable contri- bution deduction of $64,490,000. In order to substantiate a charitable contribution deduction of $250 or more, a taxpayer must secure and maintain in its files a “contemporaneous written acknowledgment” (CWA) from the donee organiza..

Docket No. 31197-12 Amazon.com, Inc. v. Comm'r (2017)

United States Tax Court Filed: Mar. 23, 2017

148 T.C. No. 8 UNITED STATES TAX COURT AMAZON.COM, INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 31197-12. Filed March 23, 2017. In 2005 P entered into a cost sharing arrangement (CSA) with S, its Luxembourg subsidiary. Pursuant to the CSA, P granted S the right to use certain pre-existing intangible assets in Europe, including the intangibles required to operate P’s European website business. This arrangement required S to make an upfront “buy-in paym..

Alison H. Haskins