Legal Opinion
Alioto v. Comm'r
United States Tax Court
Decided July 31, 2008No. 14356-03UnpublishedCited by 11 opinions
1Opinion of the Court
KATHLEEN SULLIVAN ALIOTO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Alioto v. Comm'r
No. 14356-03
United States Tax Court
T.C. Memo 2008-185; 2008 Tax Ct. Memo LEXIS 181; 96 T.C.M. (CCH) 63;
July 31, 2008, Filed
Alioto v. Comm'r, T.C. Memo 2006-199, 2006 Tax Ct. Memo LEXIS 202 (T.C., 2006)
The court held that petitioner satisfied the safe harbor conditions in Rev. Proc. 2000-15, § 4.02, and that the IRS's contrary determination was an abuse of discretion in that it was arbitrary, capricious, and without sound basis in law or fact. It thereupon ruled that petitioner was entitled to…
2Cases cited30 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Gallick v. Baltimore & Ohio RailroadSupreme Court of the United States · 1963
- Tokarski v. CommissionerUnited States Tax Court · 1986
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Petzoldt v. CommissionerUnited States Tax Court · 1989
25 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Intermountain Insurance Service of Vail, Ltd. Liability Co. v. CommissionerUnited States Tax Court · 2010
- Angle v. Comm'rUnited States Tax Court · 2016
- Barry S. Friedberg & Charlotte Moss v. CommissionerUnited States Tax Court · 2013
- Friedberg v. Comm'rUnited States Tax Court · 2013
- Intermountain Insurance Service of Vail, Ltd. Liability Co. v. CommissionerUnited States Tax Court · 2010
6 more not listed; retrieve them via the Exa API.