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Docket No. 2400-96 Hamm v. Commissioner (1997)

United States Tax Court Filed: Aug. 05, 1997

T.C. Memo. 1997-358 UNITED STATES TAX COURT JOYCE M. AND THOMAS J. HAMM, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 2400-96. Filed August 5, 1997. Joyce M. Hamm and Thomas J. Hamm, pro sese. Amy A. Campbell, for respondent. MEMORANDUM OPINION WELLS, Judge: This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121(a).1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year..

No. 5057-04S POWERS v. COMMISSIONER (2005)

United States Tax Court Filed: Feb. 23, 2005

T.C. Summary Opinion 2005-21 UNITED STATES TAX COURT SHIRLEY DEAN POWERS, a.k.a. SHIRLEY POWERS GILCHRIST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5057-04S. Filed February 23, 2005. Shirley Dean Powers, a.k.a. Shirley Powers Gilchrist, pro se. Innessa Glazman Molot, for respondent. PANUTHOS, Chief Special Trial Judge: This case was heard pursuant to the provisions of sections 6330(d) and 7463.1 The decision to be entered is not reviewable by any other court, and this..

Docket No. 5031-94 Apollo Overseas Int'l v. Commissioner (1996)

United States Tax Court Filed: Jun. 17, 1996

T.C. Memo. 1996-280 UNITED STATES TAX COURT APOLLO OVERSEAS INTERNATIONAL, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5031-94. Filed June 17, 1996. James S. Yan, for petitioner. Clifton B. Cates III and Nancy C. McCurley, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION SCOTT, Judge: Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax for the taxable years ended January 31, 1988, 1989, and 1990, as follows: -2 - Ad..

Nos. 1327-02, 1129-03 McClelland v. Comm'r (2005)

United States Tax Court Filed: May 24, 2005

T.C. Memo. 2005-121 UNITED STATES TAX COURT EUGENE MCCLELLAND AND IONE MCCLELLAND, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 1327-02, 1129-03. Filed May 24, 2005. Paul V. Sween, for petitioner Eugene McClelland. William A. Vincent, for petitioner Ione McClelland. Blaine Holiday, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: By separate notices of deficiency, respondent determined deficiencies in petitioners’ Federal income tax of $345,037 for ..

No. 21954-05 Stockwell v. Comm'r (2007)

United States Tax Court Filed: Jun. 13, 2007

T.C. Memo. 2007-149 UNITED STATES TAX COURT LEONARD STOCKWELL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21954-05. Filed June 13, 2007. Leonard Stockwell, pro se. Lisa R. Woods, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION KROUPA, Judge: Respondent determined a $5,588 deficiency in petitioner’s Federal income tax for 2003. After concessions,1 we are asked to decide two issues. First, we are asked to decide whether petitioner was away from home when he worked..

No. 10084-04 Kemper v. Comm'r (2007)

United States Tax Court Filed: Nov. 28, 2007

T.C. Memo. 2007-353 UNITED STATES TAX COURT JENNIFER J. KEMPER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10084-04. Filed November 28, 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 ..

No. 16342-04 Rodriguez v. Comm'r (2009)

United States Tax Court Filed: Jan. 29, 2009

T.C. Memo. 2009-22 UNITED STATES TAX COURT JOHN M. RODRIGUEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16342-04. Filed January 29, 2009. Jerry B. Register, for petitioner. Randall Durfee, for respondent. MEMORANDUM OPINION HOLMES, Judge: John Rodriguez is a real-estate sales manager who also had personal real-estate investments. He did not file income tax returns from 1998 through 2001. The IRS noticed, and created “substitutes for returns” (SFRs) for him, calculating..

No. 11530-04S Jayesh B. v. Comm'r (2006)

United States Tax Court Filed: Mar. 16, 2006

T.C. Summary Opinion 2006-40 UNITED STATES TAX COURT JAYESH B. AND DEVSMITA J. PATEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11530-04S. Filed March 16, 2006. Jayesh B. and Devsmita J. Patel, pro sese. Clare J. Brooks, 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. The decision to be entered is not reviewable by any other court, a..

No. 24079-06 Haubrich v. Comm'r (2008)

United States Tax Court Filed: Dec. 30, 2008

T.C. Memo. 2008-299 UNITED STATES TAX COURT GREGORY H. HAUBRICH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 24079-06. Filed December 30, 2008. Frederick J. O’Laughlin, for petitioner. William F. Castor, for respondent. MEMORANDUM OPINION MARVEL, Judge: Petitioner timely petitioned this Court for redetermination of an income tax deficiency of $2,245 for 2004 determined by respondent in a notice of deficiency dated August 22, 2006. The deficiency is attributable to the di..

No. 16059-99 AL Trust v. Commissioner (2000)

United States Tax Court Filed: Aug. 29, 2000

T.C. Memo. 2000-276 UNITED STATES TAX COURT AL TRUST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16059-99. Filed August 29, 2000. Cheryl R. Frank and Gerald W. Kelly, for petitioner.1 Mary Ann Waters, for respondent. MEMORANDUM OPINION LARO, Judge: Respondent moves the Court to dismiss this case for lack of jurisdiction, arguing that the petition was not filed with the Court by a proper party as required by Rule 1 Ms. Frank and Mr. Kelly entered their appearance on July..

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