T.C. Memo. 2008-209 UNITED STATES TAX COURT DIANE J. SANDERLIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 13612-07. Filed August 28, 2008. Diane J. Sanderlin, pro se. Nhi T. Luu, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION COHEN, Judge: Respondent determined deficiencies and penalties with respect to petitioner’s Federal income taxes as follows: - 2 - Penalty Year Deficiency Sec. 6662(a) 2003 $3,689 $738 2004 3,389 678 2005 2,305 461 The issues for decisi..
T.C. Memo. 2007-191 UNITED STATES TAX COURT DUANE R. SUNDIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10885-04. Filed July 17, 2007. Larry D. Harvey, for petitioner. Randall L. Preheim, for respondent. MEMORANDUM OPINION VASQUEZ, Judge: This case is before the Court on respondent’s motion for summary judgment pursuant to Rule 121.1 1 Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to ..
T.C. Summary Opinion 2007-77 UNITED STATES TAX COURT MARY ELIZABETH CUMINGS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11623-05S. Filed May 21, 2007. Mary Elizabeth Cumings, pro se. Michael W. Lloyd, for respondent. MARVEL, 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 entered is not reviewable by any other court, and 1 All subseq..
T.C. Memo. 2006-213 UNITED STATES TAX COURT JOHN N. SWEENEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21167-05L. Filed October 3, 2006. John N. Sweeney, pro se. Monica J. Miller, for respondent. MEMORANDUM OPINION WELLS, Judge: The instant case is before the Court on respondent’s motion for summary judgment pursuant to Rule 1211 and to impose a penalty pursuant to section 6673. The issue we 1 Unless otherwise indicated, all Rule references are to the Tax Court Rules o..
198 U.S. 280 (1905) FIRST NATIONAL BANK OF CHICAGO v. CHICAGO TITLE & TRUST COMPANY. No. 139. Supreme Court of United States. Argued January 19, 20, 1905. Decided May 15, 1905. CERTIORARI TO THE CIRCUIT COURT OF APPEALS FOR THE SEVENTH CIRCUIT. *285 Mr. Henry S. Robbins, with whom Mr. Wallace Heckman and Mr. James G. Elsdon were on the brief, for petitioners. Mr. Joseph E. Paden and Mr. Newton Wyeth, with whom Mr. James H. Reed and Mr. James H. Beal were on the brief, for respondents. *288 MR. CH..
197 U.S. 230 (1905) BARTLETT v. UNITED STATES. No. 259. Supreme Court of United States. Submitted February 27, 1905. Decided March 13, 1905. APPEAL FROM THE COURT OF CLAIMS. Mr. J.M. Vale for appellant. Mr. Assistant Attorney General Pradt and Mr. Special Attorney Frederick de C. Faust for the United States. *232 MR. JUSTICE HOLMES delivered the opinion of the court. This is an appeal from a judgment of the Court of Claims rejecting the claim of the appellant. 39 Cow. Cl . 338. The claimant while..
