Legal Opinion
Norman Hinerfeld v. Commissioner
United States Tax Court
Decided May 2, 2019No. 4879-15LUnpublished
1Opinion of the Court
T.C. Memo. 2019-47
UNITED STATES TAX COURT NORMAN HINERFELD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 4879-15L. Filed May 2, 2019. R's Appeals Office (Appeals) rejected P's offer to settle his liability for trust fund recovery penalties because it did not reflect the value of his residence, L, title to which he had previously transferred to his wife, W. Held: Upholding a determination by Appeals that lacks an adequate explanation does not violate the doctrine of SEC v. Chenery Corp.,
318 U.S. 80
(1943), when the failure of explanation relates to a legal issue rather…
2Cases cited28 opinions
- Securities & Exchange Commission v. Chenery Corp.Supreme Court of the United States · 1947
- Securities & Exchange Commission v. Chenery Corp.Supreme Court of the United States · 1943
- Bowman Transportation, Inc. v. Arkansas-Best Freight System, Inc.Supreme Court of the United States · 1975
- Camp v. PittsSupreme Court of the United States · 1973
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
23 more not listed; retrieve them via the Exa API.