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ELLIS v. COMMISSIONER OF INTERNAL REVENUE, 14 T.C. 484 (1950) , 14 T.C. 484 (1950)

Docket No. 22376.United States Tax Court. Promulgated March 27, 1950. , such as in a United States District Court or in the United States Court of Claims, and, thereafter, the taxpayer files a petition in the Tax Court of in a United States District Court or in the United States Court of Claims to recover any alleged overpayment of tax.

Daniel-Gerard-Callahan-V-Commissioner , tax daniel-gerard-callahan-v-commissioner (2014)

Memo. 2010-201 UNITED STATES TAX COURT DANIEL GERARD CALLAHAN, Petitioner v. of the United States. United States v. Hilgeford, 7 F.3d 1340 (7th Cir. 1993); United States v. Gerads, 999 F.2d 1255 (8th Cir. 1993); United States v.

CALLAHAN v. COMMISSIONER, 2010-201 (T.C.M. 9-14-2010) , 9ed36c32b5dcd51b (2010)

COMMISSIONER OF INTERNALREVENUE, Respondent No. 12907-08.United States Tax Court. Filed September 14, 2010. United States v. Hilgeford,7 F.3d 1340 (7th Cir. 1993); United States v. Gerads,999 F.2d 1255 (8th Cir. 1993); United States v. " are defined under other United States Code titles and are unrelated to income tax.

CARBORUNDUM CO. v. COMMISSIONER OF INTERNAL REVENUE, 58 T.C. 909 (1972) , 58 T.C. 909 (1972)

COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 7779-70.United States Tax Court. Filed August 28, 1972. Petitioner elected, under art. In 1946, the result in Biddle was changed by the United States-United Kingdom Income Tax Convention, effective, as respects United States tax, for taxable See brief of the United States in the Court of Appeals, p. 22, fn. 26.

Estate-Of-Frank-A-Branson-V-Commissioner , tax estate-of-frank-a-branson-v-commissioner (2015)

United States, 276 F.2d at 23. The Court of Claims did not cite United States v. Herring, supra, and United States v. - 60 - LARO, J., concurring: The United States Tax Court is a court of law that, like the United States District Tax Court of the United States, unlike a District Court, was without authority to vacate a final decision.

ESTATE OF BRANSON v. COMMISSIONER, 113 T.C. 6 (1999) , 113 T.C. 6 (1999)

COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10028-95.United States Tax Court. Filed July 13, 1999. United States, 276 F.2d at 23. The Court of Claims did not cite United States v. Herring, supra, and United States v. LARO, J., concurring: The United States Tax Court is a court of law that, like the United States District Courts, has the authority to apply equitable

Estate-Of-Bessie-I-Mueller-John-S-Mueller-Personal-Representative-V , tax estate-of-bessie-i-mueller-john-s-mueller-personal-representative-v (2014)

No. 13 UNITED STATES TAX COURT ESTATE OF BESSIE I. MUELLER, DECEASED, JOHN S. United States, 276 F.2d at 23. The Court of Claims did not cite United States v. Herring and United States v. Bowcut, and Rev. United States, the United States Supreme Court emphasized other language in Commissioner v.

SAVARY v. COMMISSIONER OF INTERNAL REVENUE, 2010-150 (T.C. 10-6-2010) , 885086af545a1047 (2010)

COMMISSIONER OF INTERNAL REVENUE,Respondent No. 6839-09S.United States Tax Court. Filed October 6, 2010. The issues for decision are: (1) Whether, pursuant to an income tax convention between the United States and France, the United States is precluded from ) the United States shall allow as a credit against the United States income tax the French income taxPage 9 paid" after certain credits which are not

ESTATE OF KAHN v. COMMISSIONER OF INTERNAL REVENUE, 60 T.C. 964 (1973) , 60 T.C. 964 (1973)

States Tax Court. States or those guaranteed by the United States. States to receive United States bonds for security in cases authorized by existing laws.

DORL v. COMMISSIONER OF INTERNAL REVENUE, 57 T.C. 720 (1972) , 57 T.C. 720 (1972)

COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 6392-71.United States Tax Court. Filed March 6, 1972. Where, as here, a taxpayer receives a notice of an income tax deficiency and files a timely petition with the United States Tax Court, he gives the Tax United States, 247 F. Supp. 611 (D.N.Y. 1965); McDonald v. United States (M.D.

ELIAS v. COMMISSIONER OF INTERNAL REVENUE, 100 T.C. 510 (1993) , 100 T.C. 510 (1993)

Nos. 706-92, 707-92, 708-92, 709-92, 710-92, 711-92.United States Tax Court. Filed June 8, 1993. the United States, the United States did not waive its sovereign immunity, and the State court had no jurisdiction over the United States. States in a district court of the United States.

Lisa-Hamilton-Savary-V-Commissioner , tax lisa-hamilton-savary-v-commissioner (2014)

Summary Opinion 2010-150 UNITED STATES TAX COURT LISA HAMILTON SAVARY, Petitioner v. United States income tax: (i) the French income tax paid by or on behalf of such citizen”. (i) the United States shall allow as a credit against the United States income tax the French income tax - 9 - paid”

BURNS, STIX FRIEDMAN CO. v. COMMR. OF INTERNAL REV., 57 T.C. 392 (1971) , 57 T.C. 392 (1971)

"The United States Tax Court * * * is a continuation of the Tax Court of the United States as it existed prior to the date of enactment of this Act * * Court of the United States and the Board of Tax Appeals. [fn3] The name of this Court was changed from Tax Court of the United States to United States Tax Court by the Tax Reform Act.

PALATINE INSURANCE CO., LTD. v. COMMR. OF INTERNAL REV., 4 T.C. 239 (1944) , 4 T.C. 239 (1944)

Docket No. 2446.United States Tax Court. Promulgated October 23, 1944. United States, supra, the court thought it "proper that some limitation should be placed upon the amount of foreign taxes paid by a member of a consolidated that no tax whatever would be paid to the United States."

CROW v. COMMISSIONER OF INTERNAL REVENUE, 85 T.C. 376 (1985) , 85 T.C. 376 (1985)

No. 32439-83.United States Tax Court. Filed August 26, 1985. OPINION COHEN, Judge: This case is before the Court on petitioner's motion for summary judgment under Rule 121, Tax Court Rules of Practice and establish a distinctly brighter tax picture in the United States for the foreigner.

MINUTO v. COMMISSIONER OF INTERNAL REVENUE, 66 T.C. 616 (1976) , 66 T.C. 616 (1976)

COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket No. 190-76.United States Tax Court. Filed June 28, 1976. States District Court, Washington, D.C., not to be properly addressed to the Clerk of the United States Tax Court, and Abbott Hoffman, 63 T.C. 638 (1975 in 1969 from Tax Court of the United States to United States Tax Court.

John-L-Leathley-V-Commissioner , tax john-l-leathley-v-commissioner (2013)

Memo. 2010-194 UNITED STATES TAX COURT JOHN L. LEATHLEY, Petitioner v. United States, supra at 1543-1544, the court held both that accrued interest on a nondischargeable tax debt is nondischargeable and that tax fraud penalties United States, supra at 1552, the court concluded that 11 U.S.C. section 523(a)(7)(B) extinguished liability only for tax penalties and not for interest

IANNIELLO v. COMMISSIONER OF INTERNAL REVENUE, 98 T.C. 165 (1992) , 98 T.C. 165 (1992)

Nos. 29249-86, 37909-86, 37910-86.United States Tax Court. Filed February 24, 1992. The Supreme Court recentlyPage 179 stated in United States v. United States, supra, the Supreme Court considered whether the Double Jeopardy Clause barred a civil action by the United States for liquidated damages

ESTATE OF JANDORF v. COMMISSIONER OF INTERNAL REVENUE, 9 T.C. 338 (1947) , 9 T.C. 338 (1947)

Docket No. 9327.United States Tax Court. Promulgated September 12, 1947. United States, which were issued after March 1, 1941, and were physically located in the United States, are subject to estate tax. States which is situated in the United States shall be included in the gross estate subject to tax.

LURKINS v. COMMISSIONER OF INTERNAL REVENUE, 49 T.C. 452 (1968) , 49 T.C. 452 (1968)

to "The Tax Court of the United States" by statute in 1942. Rule 1(b), Tax Court Rules of Practice, clearly provides that all mail sent to the Court should be addressed to: Tax Court of the United States, Box 70 as the Tax Court of the United States.

ROSS v. COMMISSIONER OF INTERNAL REVENUE, 38 T.C. 309 (1962) , 38 T.C. 309 (1962)

Docket No. 175-62.United States Tax Court. Filed May 22, 1962. United States District Court for the Southern District of New York relative to the income tax liability for these years pursuant to section 7403 of the of the United States to enforce the lien of the United States under this title with respect to such tax or liability or to subject any property, of whatever

Robert-J-Bivolcic-V-Commissioner , tax robert-j-bivolcic-v-commissioner (2013)

Memo. 2000-62 UNITED STATES TAX COURT ROBERT J. BIVOLCIC, Petitioner v. Regarding tax years different from those in the above mentioned case, the U.S. District Court for the District of New Jersey, in United States v. The action was dismissed by the United States District Court, and on his appeal, the United States Court of Appeals for the Third Circuit affirmed the

Jorge-Zamora-Quezada-V-Commissioner , tax jorge-zamora-quezada-v-commissioner (2014)

Memo. 1997-481 UNITED STATES TAX COURT JORGE ZAMORA-QUEZADA, Petitioner v. United States v. Boyle, supra at 245. It is clear that the Federal income tax reaches income that is earned in the United States by an alien even if deemed a nonresident.

FILLER v. COMMISSIONER, 74 T.C. 406 (1980) , 74 T.C. 406 (1980)

COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 8767-76.United States Tax Court. Filed May 27, 1980. [fn4] Certainly, this Court is not empowered to initiate any competent authority proceedings or to represent the United States in any negotiations with receiving such income from United States sources a tax credit corresponding to the amount of tax levied in the United States.

Ed-M-Fisher-V-Commissioner , tax ed-m-fisher-v-commissioner (2013)

Memo. 1996-277 UNITED STATES TAX COURT ED M. FISHER, Petitioner v. Petitioner is a taxpayer and is subject to the income tax laws of the United States. United States v. United States, 755 F.2d 517, 519 (7th Cir. 1984).

Stanley-Battat-Zmira-Battat-V-Commissioner , tax stanley-battat-zmira-battat-v-commissioner (2014)

of the Tax Court of the United States. as the United States Tax Court. States, a court of record to be known as the United States Tax Court.

David-Roy-Callihan-V-Commissioner , tax david-roy-callihan-v-commissioner (2014)

Memo. 2011-268 UNITED STATES TAX COURT DAVID ROY CALLIHAN, Petitioner v. The contention that the 50 States are not part of the “United States” is a thoroughly discredited and frivolous argument. See United States v. Section 3121 pertains to employment taxes (not Federal income tax) and states to clarify that the “United - 4 - States

Tom-And-Louise-Kappus-V-Commissioner , tax tom-and-louise-kappus-v-commissioner (2013)

Memo. 2002-36 UNITED STATES TAX COURT TOM AND LOUISE KAPPUS, Petitioners v. 3) in the United States, except that such deduction need not exceed the amount of the tax that would be paid to the United States if the resident were not a United States citizen; and (b) For the purposes of computing the United States tax, the United States shall allow

WILSON v. COMMISSIONER OF INTERNAL REVENUE, 7 T.C. 1469 (1946) , 7 T.C. 1469 (1946)

Docket No. 5407.United States Tax Court. Promulgated December 31, 1946. , as construed by the United States courts (Burnet v. United States.

Dale-Curtis-Kinslow-V-Commissioner , tax dale-curtis-kinslow-v-commissioner (2014)

Memo. 2002-313 UNITED STATES TAX COURT DALE CURTIS KINSLOW, Petitioner v. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay to the United States a penalty, up to $25,000, whenever it appears that proceedings United States pursuant to section 6673(a)

Zhengnan Shi v. Commissioner , zhengnan-shi-v-commissioner (2014)

Memo. 2014-173 UNITED STATES TAX COURT ZHENGNAN SHI, Petitioner v. of the United States in 2009 from the United States.

Richard-A-Paikowski-V-Commissioner , tax richard-a-paikowski-v-commissioner (2014)

Summary Opinion 2006-48 UNITED STATES TAX COURT RICHARD A. PAIKOWSKI, Petitioner v. United States, 435 U.S. 21, 25 (1978); United States v. Basye, 410 U.S. 441, 449 (1973). United States, 775 F.2d 887, 889 (7th Cir. 1985); see Cent. Ill. Pub. Serv. Co. v. United States, supra.

William-D-And-Judith-A-Jamieson-V-Commissioner , tax william-d-and-judith-a-jamieson-v-commissioner (2014)

Memo. 2008-118 UNITED STATES TAX COURT WILLIAM D. AND JUDITH A. JAMIESON, Petitioners v. States if the resident were not a United States citizen; and (b) For the purposes of computing the United States tax, the United States shall allow as a credit against United States tax the income tax paid or accrued to Canada after the deduction referred to in subparagraph

SMETANKA v. COMMISSIONER, 74 T.C. 715 (1980) , 74 T.C. 715 (1980)

COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket No. 17580-79.United States Tax Court. Filed July 17, 1980. United States Tax Court Washington, D.C. 91217 The envelope containing the petition was received at the Tax Court on December 26, 1979, and a stamp on Petitioners argue that the address used by the Tax Court on orders and on envelopes merely shows "United States Tax Court, Washington, D.C. 20217," without

HARRIS v. COMMISSIONER OF INTERNAL REVENUE, 10 T.C. 741 (1948) , 10 T.C. 741 (1948)

Docket No. 11616.United States Tax Court. Promulgated April 30, 1948. 1. the United States. States and then make a gift free from United States gift tax.

Estate-Of-Avrom-A-Silver-Bonny-Fern-Silver-Kenneth-Kirsh-And-Ronald , tax estate-of-avrom-a-silver-bonny-fern-silver-kenneth-kirsh-and-ronald (2013)

No. 14 UNITED STATES TAX COURT ESTATE OF AVROM A. Court Rules of Practice and Procedure Upon decedent’s death, the estate filed a Form 706NA, United States Estate (and Generation Skipping Transfer) Tax Return (tax return).

ESTATE OF VRINIOTIS v. COMMISSIONER OF INTERNAL REVENUE, 79 T.C. 298 (1982) , 79 T.C. 298 (1982)

No. 11353-78.United States Tax Court. Filed August 11, 1982. The Court reasoned that since the United States Government benefits its citizens and their property wherever found, its power to tax them is based on their property situated in the United States was exempt from Greek inheritance tax.

ESTATE OF SILVER v. COMMISSIONER, INTERNAL REV., 120 T.C. 430 (2003) , 120 T.C. 430 (2003)

Docket No. 10125-01.United States Tax Court. Filed May 14, 2003. D was not a citizen or resident of the United States. Holland, Legislative History of United States Tax Conventions 1366, 1403 (1996). Holland, Legislative History of United States Tax Conventions 1366 (1996).

George-C-Huff-V-Commissioner , tax george-c-huff-v-commissioner (2014)

STATES TAX COURT REPORTS (222) 1986), Pub. STATES TAX COURT REPORTS (222) III. STATES TAX COURT REPORTS (222) Islands tax obligations under section 932

ESTATE OF RIVERA v. COMMISSIONER OF INTERNAL REVENUE, 19 T.C. 271 (1952) , 19 T.C. 271 (1952)

Docket No. 36335.United States Tax Court. Promulgated November 21, 1952. This Court held that Part II of the estate tax law (sections 810 to 851, I. R. United States. 8 U.S.C. § 602.

DAVIES CO. v. COMMISSIONER OF INTERNAL REVENUE, 75 T.C. 443 (1980) , 75 T.C. 443 (1980)

No. 8491-78.United States Tax Court. Filed December 29, 1980. the United States. United States, 530 F.2d at 873.

Russell-W-Coulton-V-Commissioner , tax russell-w-coulton-v-commissioner (2014)

Memo. 2005-199 UNITED STATES TAX COURT RUSSELL W. COULTON, Petitioner v. See United States v. Mosel, 738 F.2d 157 (6th Cir. 1984); United States v. Smith, 618 F.2d 280 (5th Cir. 1980); United States v. United States v. Moore, supra.

FREESEN v. COMMISSIONER OF INTERNAL REVENUE, 89 T.C. 1123 (1987) , 89 T.C. 1123 (1987)

No. 16104-83.United States Tax Court. Filed December 8, 1987. Generally, the Federal Rules of Appellate Procedure are applicable to the Tax Court as if it were a District Court of the United States. See rule 14. States.28 U.S.C. § 1920 (1982) provides as follows: A judge or clerk of any court of the United States may tax as costs the following: (1) Fees

CALLIHAN v. COMMISSIONER, 2011-268 (T.C.M. 11-10-2011) , 379df3fcdd17da85 (2011)

COMMISSIONER OF INTERNAL REVENUE,Respondent No. 14506-10.United States Tax Court. Filed November 10, 2011. The contention that the 50 States are not part of the "United States" is a thoroughly discredited and frivolous argument. frivolous or groundless, to pay a penalty of up to $25,000 to the United States.

Robert-M-And-Pamela-Price-V-Commissioner , tax robert-m-and-pamela-price-v-commissioner (2014)

Memo. 2002-215 UNITED STATES TAX COURT ROBERT M. AND PAMELA PRICE, Petitioners v. the general principle hereof), the United States shall allow to a citizen or resident of the United States, or to a company electing to the United States tax, the United States shall allow as a credit against United States tax the income tax paid or accrued to Canada after

GLEASON WORKS v. COMMISSIONER OF INTERNAL REVENUE, 58 T.C. 464 (1972) , 58 T.C. 464 (1972)

COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 2651-70.United States Tax Court. Filed June 15, 1972. In 1946, the result in Biddle was changed by the United States-United Kingdom Income Tax Convention, effective, as respects United States tax, for taxable of United States tax the amount of such United Kingdom income tax. [60 Stat. 1377, 1384.

Emmanuel-L-Roco-V-Commissioner , tax emmanuel-l-roco-v-commissioner (2014)

No. 10 UNITED STATES TAX COURT EMMANUEL L. ROCO, Petitioner v. Petitioner’s 1997 Tax Returns Petitioner made no estimated tax payments to the United States in 1997 relating to the qui tam payment, but he did Bruun, 309 U.S. 461 (1940); United States v. Kirby Lumber Co., 284 U.S. 1 (1931). The Supreme Court has limited Eisner v.

ROCO v. COMMISSIONER, 121 T.C. 160 (2003) , 121 T.C. 160 (2003)

Docket No. 8470-01.United States Tax Court. Filed September 11, 2003. United States ex rel. Semtner v. Bruun, 309 U.S. 461 (1940); United States v. Kirby Lumber Co., 284 U.S. 1 (1931). The Supreme Court has limited Eisner v.

ESTATE OF CADWALLADER v. COMMR. OF INTERNAL REVENUE, 13 T.C. 214 (1949) , 13 T.C. 214 (1949)

Docket Nos. 798, 803.United States Tax Court. Promulgated August 19, 1949. 1. sources of income within the United States. 4. The Cadwallader-Gibson Lumber Co. did not file any United States income or profits tax returns and did not pay any United States income or profits taxes

Estate-Of-Travis-L-Sanders-Thomas-S-Hogan-Jr-Personal-Representative , tax estate-of-travis-l-sanders-thomas-s-hogan-jr-personal-representative (2014)

Participating companies of the EDP receive substantial tax benefits, including a 90% exemption on local taxes. 66 144 UNITED STATES TAX COURT States as income from sources within in the 70 144 UNITED STATES TAX COURT REPORTS (63) USVI * * * in order to 80 144 UNITED STATES TAX COURT REPORTS (63) place of business in the United States to file his or her tax return as designated

Opinion

ELLIS v. COMMISSIONER OF INTERNAL REVENUE, 14 T.C. 484 (1950) , 14 T.C. 484 (1950)

Docket No. 22376.United States Tax Court. Promulgated March 27, 1950. , such as in a United States District Court or in the United States Court of Claims, and, thereafter, the taxpayer files a petition in the Tax Court of in a United States District Court or in the United States Court of Claims to recover any alleged overpayment of tax.

Daniel-Gerard-Callahan-V-Commissioner , tax daniel-gerard-callahan-v-commissioner (2014)

Memo. 2010-201 UNITED STATES TAX COURT DANIEL GERARD CALLAHAN, Petitioner v. of the United States. United States v. Hilgeford, 7 F.3d 1340 (7th Cir. 1993); United States v. Gerads, 999 F.2d 1255 (8th Cir. 1993); United States v.

CALLAHAN v. COMMISSIONER, 2010-201 (T.C.M. 9-14-2010) , 9ed36c32b5dcd51b (2010)

COMMISSIONER OF INTERNALREVENUE, Respondent No. 12907-08.United States Tax Court. Filed September 14, 2010. United States v. Hilgeford,7 F.3d 1340 (7th Cir. 1993); United States v. Gerads,999 F.2d 1255 (8th Cir. 1993); United States v. " are defined under other United States Code titles and are unrelated to income tax.

CARBORUNDUM CO. v. COMMISSIONER OF INTERNAL REVENUE, 58 T.C. 909 (1972) , 58 T.C. 909 (1972)

COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 7779-70.United States Tax Court. Filed August 28, 1972. Petitioner elected, under art. In 1946, the result in Biddle was changed by the United States-United Kingdom Income Tax Convention, effective, as respects United States tax, for taxable See brief of the United States in the Court of Appeals, p. 22, fn. 26.

Estate-Of-Frank-A-Branson-V-Commissioner , tax estate-of-frank-a-branson-v-commissioner (2015)

United States, 276 F.2d at 23. The Court of Claims did not cite United States v. Herring, supra, and United States v. - 60 - LARO, J., concurring: The United States Tax Court is a court of law that, like the United States District Tax Court of the United States, unlike a District Court, was without authority to vacate a final decision.

ESTATE OF BRANSON v. COMMISSIONER, 113 T.C. 6 (1999) , 113 T.C. 6 (1999)

COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10028-95.United States Tax Court. Filed July 13, 1999. United States, 276 F.2d at 23. The Court of Claims did not cite United States v. Herring, supra, and United States v. LARO, J., concurring: The United States Tax Court is a court of law that, like the United States District Courts, has the authority to apply equitable

Estate-Of-Bessie-I-Mueller-John-S-Mueller-Personal-Representative-V , tax estate-of-bessie-i-mueller-john-s-mueller-personal-representative-v (2014)

No. 13 UNITED STATES TAX COURT ESTATE OF BESSIE I. MUELLER, DECEASED, JOHN S. United States, 276 F.2d at 23. The Court of Claims did not cite United States v. Herring and United States v. Bowcut, and Rev. United States, the United States Supreme Court emphasized other language in Commissioner v.

SAVARY v. COMMISSIONER OF INTERNAL REVENUE, 2010-150 (T.C. 10-6-2010) , 885086af545a1047 (2010)

COMMISSIONER OF INTERNAL REVENUE,Respondent No. 6839-09S.United States Tax Court. Filed October 6, 2010. The issues for decision are: (1) Whether, pursuant to an income tax convention between the United States and France, the United States is precluded from ) the United States shall allow as a credit against the United States income tax the French income taxPage 9 paid" after certain credits which are not

ESTATE OF KAHN v. COMMISSIONER OF INTERNAL REVENUE, 60 T.C. 964 (1973) , 60 T.C. 964 (1973)

States Tax Court. States or those guaranteed by the United States. States to receive United States bonds for security in cases authorized by existing laws.

DORL v. COMMISSIONER OF INTERNAL REVENUE, 57 T.C. 720 (1972) , 57 T.C. 720 (1972)

COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 6392-71.United States Tax Court. Filed March 6, 1972. Where, as here, a taxpayer receives a notice of an income tax deficiency and files a timely petition with the United States Tax Court, he gives the Tax United States, 247 F. Supp. 611 (D.N.Y. 1965); McDonald v. United States (M.D.

ELIAS v. COMMISSIONER OF INTERNAL REVENUE, 100 T.C. 510 (1993) , 100 T.C. 510 (1993)

Nos. 706-92, 707-92, 708-92, 709-92, 710-92, 711-92.United States Tax Court. Filed June 8, 1993. the United States, the United States did not waive its sovereign immunity, and the State court had no jurisdiction over the United States. States in a district court of the United States.

Lisa-Hamilton-Savary-V-Commissioner , tax lisa-hamilton-savary-v-commissioner (2014)

Summary Opinion 2010-150 UNITED STATES TAX COURT LISA HAMILTON SAVARY, Petitioner v. United States income tax: (i) the French income tax paid by or on behalf of such citizen”. (i) the United States shall allow as a credit against the United States income tax the French income tax - 9 - paid”

BURNS, STIX FRIEDMAN CO. v. COMMR. OF INTERNAL REV., 57 T.C. 392 (1971) , 57 T.C. 392 (1971)

"The United States Tax Court * * * is a continuation of the Tax Court of the United States as it existed prior to the date of enactment of this Act * * Court of the United States and the Board of Tax Appeals. [fn3] The name of this Court was changed from Tax Court of the United States to United States Tax Court by the Tax Reform Act.

PALATINE INSURANCE CO., LTD. v. COMMR. OF INTERNAL REV., 4 T.C. 239 (1944) , 4 T.C. 239 (1944)

Docket No. 2446.United States Tax Court. Promulgated October 23, 1944. United States, supra, the court thought it "proper that some limitation should be placed upon the amount of foreign taxes paid by a member of a consolidated that no tax whatever would be paid to the United States."

CROW v. COMMISSIONER OF INTERNAL REVENUE, 85 T.C. 376 (1985) , 85 T.C. 376 (1985)

No. 32439-83.United States Tax Court. Filed August 26, 1985. OPINION COHEN, Judge: This case is before the Court on petitioner's motion for summary judgment under Rule 121, Tax Court Rules of Practice and establish a distinctly brighter tax picture in the United States for the foreigner.

MINUTO v. COMMISSIONER OF INTERNAL REVENUE, 66 T.C. 616 (1976) , 66 T.C. 616 (1976)

COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket No. 190-76.United States Tax Court. Filed June 28, 1976. States District Court, Washington, D.C., not to be properly addressed to the Clerk of the United States Tax Court, and Abbott Hoffman, 63 T.C. 638 (1975 in 1969 from Tax Court of the United States to United States Tax Court.

John-L-Leathley-V-Commissioner , tax john-l-leathley-v-commissioner (2013)

Memo. 2010-194 UNITED STATES TAX COURT JOHN L. LEATHLEY, Petitioner v. United States, supra at 1543-1544, the court held both that accrued interest on a nondischargeable tax debt is nondischargeable and that tax fraud penalties United States, supra at 1552, the court concluded that 11 U.S.C. section 523(a)(7)(B) extinguished liability only for tax penalties and not for interest

IANNIELLO v. COMMISSIONER OF INTERNAL REVENUE, 98 T.C. 165 (1992) , 98 T.C. 165 (1992)

Nos. 29249-86, 37909-86, 37910-86.United States Tax Court. Filed February 24, 1992. The Supreme Court recentlyPage 179 stated in United States v. United States, supra, the Supreme Court considered whether the Double Jeopardy Clause barred a civil action by the United States for liquidated damages

ESTATE OF JANDORF v. COMMISSIONER OF INTERNAL REVENUE, 9 T.C. 338 (1947) , 9 T.C. 338 (1947)

Docket No. 9327.United States Tax Court. Promulgated September 12, 1947. United States, which were issued after March 1, 1941, and were physically located in the United States, are subject to estate tax. States which is situated in the United States shall be included in the gross estate subject to tax.

LURKINS v. COMMISSIONER OF INTERNAL REVENUE, 49 T.C. 452 (1968) , 49 T.C. 452 (1968)

to "The Tax Court of the United States" by statute in 1942. Rule 1(b), Tax Court Rules of Practice, clearly provides that all mail sent to the Court should be addressed to: Tax Court of the United States, Box 70 as the Tax Court of the United States.

ROSS v. COMMISSIONER OF INTERNAL REVENUE, 38 T.C. 309 (1962) , 38 T.C. 309 (1962)

Docket No. 175-62.United States Tax Court. Filed May 22, 1962. United States District Court for the Southern District of New York relative to the income tax liability for these years pursuant to section 7403 of the of the United States to enforce the lien of the United States under this title with respect to such tax or liability or to subject any property, of whatever

Robert-J-Bivolcic-V-Commissioner , tax robert-j-bivolcic-v-commissioner (2013)

Memo. 2000-62 UNITED STATES TAX COURT ROBERT J. BIVOLCIC, Petitioner v. Regarding tax years different from those in the above mentioned case, the U.S. District Court for the District of New Jersey, in United States v. The action was dismissed by the United States District Court, and on his appeal, the United States Court of Appeals for the Third Circuit affirmed the

Jorge-Zamora-Quezada-V-Commissioner , tax jorge-zamora-quezada-v-commissioner (2014)

Memo. 1997-481 UNITED STATES TAX COURT JORGE ZAMORA-QUEZADA, Petitioner v. United States v. Boyle, supra at 245. It is clear that the Federal income tax reaches income that is earned in the United States by an alien even if deemed a nonresident.

FILLER v. COMMISSIONER, 74 T.C. 406 (1980) , 74 T.C. 406 (1980)

COMMISSIONER OFINTERNAL REVENUE, RESPONDENT Docket No. 8767-76.United States Tax Court. Filed May 27, 1980. [fn4] Certainly, this Court is not empowered to initiate any competent authority proceedings or to represent the United States in any negotiations with receiving such income from United States sources a tax credit corresponding to the amount of tax levied in the United States.

Ed-M-Fisher-V-Commissioner , tax ed-m-fisher-v-commissioner (2013)

Memo. 1996-277 UNITED STATES TAX COURT ED M. FISHER, Petitioner v. Petitioner is a taxpayer and is subject to the income tax laws of the United States. United States v. United States, 755 F.2d 517, 519 (7th Cir. 1984).

Stanley-Battat-Zmira-Battat-V-Commissioner , tax stanley-battat-zmira-battat-v-commissioner (2014)

of the Tax Court of the United States. as the United States Tax Court. States, a court of record to be known as the United States Tax Court.

David-Roy-Callihan-V-Commissioner , tax david-roy-callihan-v-commissioner (2014)

Memo. 2011-268 UNITED STATES TAX COURT DAVID ROY CALLIHAN, Petitioner v. The contention that the 50 States are not part of the “United States” is a thoroughly discredited and frivolous argument. See United States v. Section 3121 pertains to employment taxes (not Federal income tax) and states to clarify that the “United - 4 - States

Tom-And-Louise-Kappus-V-Commissioner , tax tom-and-louise-kappus-v-commissioner (2013)

Memo. 2002-36 UNITED STATES TAX COURT TOM AND LOUISE KAPPUS, Petitioners v. 3) in the United States, except that such deduction need not exceed the amount of the tax that would be paid to the United States if the resident were not a United States citizen; and (b) For the purposes of computing the United States tax, the United States shall allow

WILSON v. COMMISSIONER OF INTERNAL REVENUE, 7 T.C. 1469 (1946) , 7 T.C. 1469 (1946)

Docket No. 5407.United States Tax Court. Promulgated December 31, 1946. , as construed by the United States courts (Burnet v. United States.

Dale-Curtis-Kinslow-V-Commissioner , tax dale-curtis-kinslow-v-commissioner (2014)

Memo. 2002-313 UNITED STATES TAX COURT DALE CURTIS KINSLOW, Petitioner v. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay to the United States a penalty, up to $25,000, whenever it appears that proceedings United States pursuant to section 6673(a)

Zhengnan Shi v. Commissioner , zhengnan-shi-v-commissioner (2014)

Memo. 2014-173 UNITED STATES TAX COURT ZHENGNAN SHI, Petitioner v. of the United States in 2009 from the United States.

Richard-A-Paikowski-V-Commissioner , tax richard-a-paikowski-v-commissioner (2014)

Summary Opinion 2006-48 UNITED STATES TAX COURT RICHARD A. PAIKOWSKI, Petitioner v. United States, 435 U.S. 21, 25 (1978); United States v. Basye, 410 U.S. 441, 449 (1973). United States, 775 F.2d 887, 889 (7th Cir. 1985); see Cent. Ill. Pub. Serv. Co. v. United States, supra.

William-D-And-Judith-A-Jamieson-V-Commissioner , tax william-d-and-judith-a-jamieson-v-commissioner (2014)

Memo. 2008-118 UNITED STATES TAX COURT WILLIAM D. AND JUDITH A. JAMIESON, Petitioners v. States if the resident were not a United States citizen; and (b) For the purposes of computing the United States tax, the United States shall allow as a credit against United States tax the income tax paid or accrued to Canada after the deduction referred to in subparagraph

SMETANKA v. COMMISSIONER, 74 T.C. 715 (1980) , 74 T.C. 715 (1980)

COMMISSIONER OF INTERNALREVENUE, RESPONDENT Docket No. 17580-79.United States Tax Court. Filed July 17, 1980. United States Tax Court Washington, D.C. 91217 The envelope containing the petition was received at the Tax Court on December 26, 1979, and a stamp on Petitioners argue that the address used by the Tax Court on orders and on envelopes merely shows "United States Tax Court, Washington, D.C. 20217," without

HARRIS v. COMMISSIONER OF INTERNAL REVENUE, 10 T.C. 741 (1948) , 10 T.C. 741 (1948)

Docket No. 11616.United States Tax Court. Promulgated April 30, 1948. 1. the United States. States and then make a gift free from United States gift tax.

Estate-Of-Avrom-A-Silver-Bonny-Fern-Silver-Kenneth-Kirsh-And-Ronald , tax estate-of-avrom-a-silver-bonny-fern-silver-kenneth-kirsh-and-ronald (2013)

No. 14 UNITED STATES TAX COURT ESTATE OF AVROM A. Court Rules of Practice and Procedure Upon decedent’s death, the estate filed a Form 706NA, United States Estate (and Generation Skipping Transfer) Tax Return (tax return).

ESTATE OF VRINIOTIS v. COMMISSIONER OF INTERNAL REVENUE, 79 T.C. 298 (1982) , 79 T.C. 298 (1982)

No. 11353-78.United States Tax Court. Filed August 11, 1982. The Court reasoned that since the United States Government benefits its citizens and their property wherever found, its power to tax them is based on their property situated in the United States was exempt from Greek inheritance tax.

ESTATE OF SILVER v. COMMISSIONER, INTERNAL REV., 120 T.C. 430 (2003) , 120 T.C. 430 (2003)

Docket No. 10125-01.United States Tax Court. Filed May 14, 2003. D was not a citizen or resident of the United States. Holland, Legislative History of United States Tax Conventions 1366, 1403 (1996). Holland, Legislative History of United States Tax Conventions 1366 (1996).

George-C-Huff-V-Commissioner , tax george-c-huff-v-commissioner (2014)

STATES TAX COURT REPORTS (222) 1986), Pub. STATES TAX COURT REPORTS (222) III. STATES TAX COURT REPORTS (222) Islands tax obligations under section 932

ESTATE OF RIVERA v. COMMISSIONER OF INTERNAL REVENUE, 19 T.C. 271 (1952) , 19 T.C. 271 (1952)

Docket No. 36335.United States Tax Court. Promulgated November 21, 1952. This Court held that Part II of the estate tax law (sections 810 to 851, I. R. United States. 8 U.S.C. § 602.

DAVIES CO. v. COMMISSIONER OF INTERNAL REVENUE, 75 T.C. 443 (1980) , 75 T.C. 443 (1980)

No. 8491-78.United States Tax Court. Filed December 29, 1980. the United States. United States, 530 F.2d at 873.

Russell-W-Coulton-V-Commissioner , tax russell-w-coulton-v-commissioner (2014)

Memo. 2005-199 UNITED STATES TAX COURT RUSSELL W. COULTON, Petitioner v. See United States v. Mosel, 738 F.2d 157 (6th Cir. 1984); United States v. Smith, 618 F.2d 280 (5th Cir. 1980); United States v. United States v. Moore, supra.

FREESEN v. COMMISSIONER OF INTERNAL REVENUE, 89 T.C. 1123 (1987) , 89 T.C. 1123 (1987)

No. 16104-83.United States Tax Court. Filed December 8, 1987. Generally, the Federal Rules of Appellate Procedure are applicable to the Tax Court as if it were a District Court of the United States. See rule 14. States.28 U.S.C. § 1920 (1982) provides as follows: A judge or clerk of any court of the United States may tax as costs the following: (1) Fees

CALLIHAN v. COMMISSIONER, 2011-268 (T.C.M. 11-10-2011) , 379df3fcdd17da85 (2011)

COMMISSIONER OF INTERNAL REVENUE,Respondent No. 14506-10.United States Tax Court. Filed November 10, 2011. The contention that the 50 States are not part of the "United States" is a thoroughly discredited and frivolous argument. frivolous or groundless, to pay a penalty of up to $25,000 to the United States.

Robert-M-And-Pamela-Price-V-Commissioner , tax robert-m-and-pamela-price-v-commissioner (2014)

Memo. 2002-215 UNITED STATES TAX COURT ROBERT M. AND PAMELA PRICE, Petitioners v. the general principle hereof), the United States shall allow to a citizen or resident of the United States, or to a company electing to the United States tax, the United States shall allow as a credit against United States tax the income tax paid or accrued to Canada after

GLEASON WORKS v. COMMISSIONER OF INTERNAL REVENUE, 58 T.C. 464 (1972) , 58 T.C. 464 (1972)

COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket No. 2651-70.United States Tax Court. Filed June 15, 1972. In 1946, the result in Biddle was changed by the United States-United Kingdom Income Tax Convention, effective, as respects United States tax, for taxable of United States tax the amount of such United Kingdom income tax. [60 Stat. 1377, 1384.

Emmanuel-L-Roco-V-Commissioner , tax emmanuel-l-roco-v-commissioner (2014)

No. 10 UNITED STATES TAX COURT EMMANUEL L. ROCO, Petitioner v. Petitioner’s 1997 Tax Returns Petitioner made no estimated tax payments to the United States in 1997 relating to the qui tam payment, but he did Bruun, 309 U.S. 461 (1940); United States v. Kirby Lumber Co., 284 U.S. 1 (1931). The Supreme Court has limited Eisner v.

ROCO v. COMMISSIONER, 121 T.C. 160 (2003) , 121 T.C. 160 (2003)

Docket No. 8470-01.United States Tax Court. Filed September 11, 2003. United States ex rel. Semtner v. Bruun, 309 U.S. 461 (1940); United States v. Kirby Lumber Co., 284 U.S. 1 (1931). The Supreme Court has limited Eisner v.

ESTATE OF CADWALLADER v. COMMR. OF INTERNAL REVENUE, 13 T.C. 214 (1949) , 13 T.C. 214 (1949)

Docket Nos. 798, 803.United States Tax Court. Promulgated August 19, 1949. 1. sources of income within the United States. 4. The Cadwallader-Gibson Lumber Co. did not file any United States income or profits tax returns and did not pay any United States income or profits taxes

Estate-Of-Travis-L-Sanders-Thomas-S-Hogan-Jr-Personal-Representative , tax estate-of-travis-l-sanders-thomas-s-hogan-jr-personal-representative (2014)

Participating companies of the EDP receive substantial tax benefits, including a 90% exemption on local taxes. 66 144 UNITED STATES TAX COURT States as income from sources within in the 70 144 UNITED STATES TAX COURT REPORTS (63) USVI * * * in order to 80 144 UNITED STATES TAX COURT REPORTS (63) place of business in the United States to file his or her tax return as designated