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Docket No. 20768-07 Cooper v. Comm'r (2010)

United States Tax Court Filed: Oct. 05, 2010

T.C. Memo. 2010-214 UNITED STATES TAX COURT MARTIN C. COOPER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20768-07. Filed October 5, 2010. Mark M. Mockensturm, for petitioner. Elizabeth R. Edberg, for respondent. MEMORANDUM OPINION PARIS, Judge: In a notice of deficiency dated June 19, 2007, respondent determined deficiencies of $80,988 and $58,193 in petitioner’s Federal income tax and accuracy-related penalties of $16,197.60 and $11,638.60 under section 6662(a)1 for ta..

No. 4569-08S Menzies v. Comm'r (2009)

United States Tax Court Filed: Dec. 15, 2009

T.C. Summary Opinion 2009-196 UNITED STATES TAX COURT IAN AND MARY A. MENZIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4569-08S. Filed December 15, 2009. Ian and Mary A. Menzies, pro sese. David Weiner and E. Abigail Raines, for respondent. GOLDBERG, 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. Pursuant to section 7463(b), the decision to be entered is not revi..

Docket No. 24413-05 Russell v. Comm'r (2011)

United States Tax Court Filed: Apr. 06, 2011

T.C. Memo. 2011-81 UNITED STATES TAX COURT PAMELA B. RUSSELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24413-05. Filed April 6, 2011. Mark E. Cedrone, for petitioner. Jack T. Anagnostis, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION WELLS, Judge: Respondent determined that petitioner was liable for a deficiency and additions to tax for failure to file timely pursuant to section 6651(a)(1) and failure to pay timely pursuant to section 6651(a)(2) for her 2001 ..

Docket No. 6429-09. Weller v. Comm'r (2011)

United States Tax Court Filed: Sep. 20, 2011

T.C. Memo. 2011-224 UNITED STATES TAX COURT WILLIAM L. WELLER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6429-09. Filed September 20, 2011. William L. Weller, pro se. Patsy A. Clarke, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Respondent determined deficiencies in petitioner’s Federal income taxes and penalties as follows: Penalty Year Deficiency Sec. 6662(a) 2005 $4,874 $974.80 2006 5,007 1,001.40 2007 1,250 250.00 - 2 - The issues for dec..

Docket No. 24212-15L Phillips v. Comm'r (2017)

United States Tax Court Filed: Jan. 11, 2017

T.C. Memo. 2017-13 UNITED STATES TAX COURT TYREE PHILLIPS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24212-15L. Filed January 11, 2017. James G. Steele, III, for petitioner. Deborah Aloof, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case petitioner seeks review pursuant to section 6330(d)(1)1 of the determination by the Internal Reve- 1 All statutory references are to the Internal Revenue Code in effect at all relevant times, ..

Docket No. 4649-16L. Grimm v. Comm'r (2017)

United States Tax Court Filed: Mar. 16, 2017

T.C. Memo. 2017-44 UNITED STATES TAX COURT DALE GRIMM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4649-16L. Filed March 16, 2017. R mailed P a notice of determination sustaining a proposed collection action. P prepared a petition, applied postage using a private postage meter, and mailed the petition to the Court. The Court did not receive the petition within 30 days of the date of the notice of determination. Further, the petition was received by the Court later than a..

Docket No. 14414-13. Brinks Gilson & Lione P.C. v. Comm'r (2016)

United States Tax Court Filed: Feb. 10, 2016

T.C. Memo. 2016-20 UNITED STATES TAX COURT BRINKS GILSON & LIONE A PROFESSIONAL CORPORATION, FORMERLY BRINKS HOFER GILSON & LIONE A PROFESSIONAL CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14414-13. Filed February 10, 2016. Held: P, an incorporated law firm, liable for accuracy-related penalties for mischaracterizing, as compensation for services, dividends paid to shareholder attorneys. P lacked substantial authority for its treatment of payments as compens..

No. 19179-08L McCollin v. Comm'r (2010)

United States Tax Court Filed: May 03, 2010

T.C. Memo. 2010-93 UNITED STATES TAX COURT SHIRLEY V. MCCOLLIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19179-08L. Filed May 3, 2010. Shirley V. McCollin, pro se. Michelle L. Maniscalco, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GALE, Judge: Pursuant to sections 6320 and 6330(d),1 petitioner seeks review of respondent’s determination to sustain a notice of Federal tax lien with respect to petitioner’s unpaid 1 Unless otherwise noted, all section referen..

28731-15W, 2965-18W Stanley H. Epstein v. Commissioner (2019)

United States Tax Court Filed: Jul. 08, 2019

T.C. Memo. 2019-81 UNITED STATES TAX COURT STANLEY H. EPSTEIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 28731-15W, 2965-18W. Filed July 8, 2019. Mark A. Ozzello, for petitioner. Terri L. Onorato, Patricia P. Davis, and Hans Famularo, for respondent. MEMORANDUM OPINION LAUBER, Judge: These consolidated whistleblower award cases are cur- rently before the Court on motions for summary judgment filed by the Internal Revenue Service (IRS or respondent). Both cases arise f..

20985-13S L Andrew Lewis Havard v. Commissioner (2014)

United States Tax Court Filed: May 15, 2014

T.C. Summary Opinion 2014-48 UNITED STATES TAX COURT ANDREW LEWIS HAVARD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20985-13S L. Filed May 15, 2014. Andrew Lewis Havard, pro se. John F. Driscoll and Thomas Alan Friday, for respondent. SUMMARY OPINION LAUBER, 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 Pur- 1 All statutory references are to the Internal Revenue Code in effect ..

Franklin John Caldwell, Jr.