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Franklin John Caldwell, Jr.
Franklin John Caldwell, Jr.
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Bar #85761(FL)     License for 14 years
Sarasota FL

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Docket No. 27849-09L  Gray v. Comm'r  (2012)
United States Tax Court Filed: Mar. 28, 2012
CAROL DIANE GRAY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 27849–09L. 1 Filed March 28, 2012. R issued and mailed to P a notice of determination con- cerning collection actions under I.R.C. secs. 6320 and/or 6330, with respect to unpaid income taxes for 1992, 1993, 1994, and 1995, on Oct. 16, 2009. The notice determined that a proposed lien and levy should be sustained. Although P had requested relief under I.R.C. sec. 6015 for the years in issue at her hearing, the n..
Docket Nos. 11409-11, 11476-11, 27722-11.  Rader v. Comm'r  (2014)
United States Tax Court Filed: Oct. 29, 2014
VIVIAN L. RADER, ET AL., 1 PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket Nos. 11409–11, 11476–11, Filed October 29, 2014. 27722–11. Ps failed to file returns for 2003–06 and 2008 (years in issue). The IRS examining agent, using the bank deposits method and information returns issued in connection with payments to P–H or to both Ps, reconstructed Ps’ income for the years in issue and determined tax deficiencies and addi- tions to tax under I.R.C. secs. 6651(a)(1) and (2) and 6..
Docket No. 4395-09  Griggs v. Comm'r  (2013)
United States Tax Court Filed: Jan. 07, 2013
T.C. Memo. 2013-2 UNITED STATES TAX COURT GERRY M. GRIGGS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4395-09. Filed January 7, 2013. Gerry M. Griggs, pro se. Derek B. Matta, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Chief Judge: Respondent determined a $21,546 deficiency in petitioner’s 2004 Federal income tax, as well as a $4,309 accuracy-related penalty under section 6662.1 After concessions, the issues for decision are: (1) whether 1 Unless o..
Docket Nos. 8966-10, 8967-10.  Austin v. Comm'r  (2013)
United States Tax Court Filed: Dec. 16, 2013
LARRY E. AUSTIN AND BELINDA AUSTIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ESTATE OF ARTHUR E. KECHIJIAN, DECEASED, SUSAN P. KECHIJIAN AND SCOTT E. HOEHN, CO-EXECUTORS, AND SUSAN P. KECHIJIAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket Nos. 8966–10, 8967–10. Filed December 16, 2013. Ps exchanged property for ostensibly restricted stock of a newly formed S corporation (S). The governing agreements provided that Ps, upon termination of employment, would ..
Docket No. 13268-10  Saunders v. Comm'r  (2012)
United States Tax Court Filed: Jul. 17, 2012
T.C. Memo. 2012-200 UNITED STATES TAX COURT KRISTOPHER R. SAUNDERS AND JESSIKA R. SAUNDERS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13268-10. Filed July 17, 2012. Kristopher R. Saunders and Jessika R. Saunders, pro se. Edward Lee Walter, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Chief Judge: Respondent determined a $2,484 deficiency in petitioners’ 2007 Federal income tax.1 After concessions, the issue for decision is 1 Unless otherwise noted..
Docket No. 29692-11S.  Brown v. Comm'r  (2013)
United States Tax Court Filed: Mar. 04, 2013
T.C. Summary Opinion 2013-21 UNITED STATES TAX COURT NICHOLAS MATTHEW BROWN AND REBEKAH BROWN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 29692-11S. Filed March 4, 2013. Nicholas Matthew Brown and Rebekah Brown, pro sese. Timothy A. Forehle, for respondent. SUMMARY OPINION HAINES, Judge: This case was heard pursuant to section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 1 Unless otherwise indicated, all section referenc..
Docket No. 12751-08S.  Gregoline v. Comm'r  (2010)
United States Tax Court Filed: Aug. 10, 2010
T.C. Summary Opinion 2010-112 UNITED STATES TAX COURT JAMES ALLEN GREGOLINE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12751-08S. Filed August 10, 2010. James Allen Gregoline, pro se. Bryan E. Sladek and Robert D. Heitmeyer, for respondent. GOLDBERG, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect at the time the petition was filed. Pursuant to section 7463(b), the decision to be entered is not ..
Docket No. 11011-10L  Karakaedos v. Comm'r  (2012)
United States Tax Court Filed: Feb. 27, 2012
T.C. Memo. 2012-53 UNITED STATES TAX COURT MATTHEW L. KARAKAEDOS AND DIANE D. KARAKAEDOS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11011-10L. Filed February 27, 2012. Matthew L. Karakaedos and Diane D. Karakaedos, pro se. Carol-Lynn E. Moran, Gloria M. Juncadella, Thomas M. Rath, and Jason M. Kuratnick, for respondent. -2- MEMORANDUM FINDINGS OF FACT AND OPINION MORRISON, Judge: The petitioners, Matthew L. Karakaedos and Diane L. Karakaedos, challenge the determina..
Docket No. 162-15S L.  Canaday v. Comm'r  (2015)
United States Tax Court Filed: Sep. 15, 2015
T.C. Summary Opinion 2015-57 UNITED STATES TAX COURT LUCREZIA IONA CANADAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 162-15S L. Filed September 15, 2015. Lucrezia Iona Canaday, pro se. Elizabeth C. Mourges, for respondent. SUMMARY OPINION GERBER, Judge: This case is subject to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to 1 Unless otherwise indicated, all section references are to the Internal Revenue C..
Docket No. 16304-08  Lowe v. Comm'r  (2010)
United States Tax Court Filed: Jun. 14, 2010
T.C. Memo. 2010-129 UNITED STATES TAX COURT STEVE LACY LOWE AND JANICE MARIE LOWE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16304-08. Filed June 14, 2010. R determined tax deficiencies and accuracy-related penalties pursuant to sec. 6662(a), I.R.C., for Ps’ 2005 and 2006 tax years. Ps and R dispute whether Ps are entitled to business expense deductions in excess of gross income from their bass fishing contest activity. Held: Ps are not entitled to the excess business..

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