Kazi v. Commissioner
United States Tax Court
R filed computations for entry of decision in these cases pursuant to Rule 155, Tax Court Rules of Practice and Procedure. Ps filed objections to R's computations for entry of decision.
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R filed computations for entry of decision in these cases pursuant to Rule 155, Tax Court Rules of Practice and Procedure. Ps filed objections to R's computations for entry of decision. Held, the Court will not consider whether Ps are entitled to a deduction for their out-of-pocket expenses related to their investment in straddle transactions because the deductibility of those expenses is a new issue involving facts not in the record that may not be considered for the first time in a Rule 155 proceeding. Rule 155(c), Tax Court Rules of Practice and Procedure.Held further, the amount of any…
1Opinion of the Court
RALPH G. KAZI AND JEAN KAZI, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Kazi v. Commissioner
Docket Nos. 10233-79, 10234-79, 10236-79, 10237-79, 10238-79, 10240-79, 10241-79, 10242-79, 10243-79, 10244-79, 13246-80, 22297-80, 23476-81, 23479-81, 16675-83
United States Tax Court
T.C. Memo 1991-37; 1991 Tax Ct. Memo LEXIS 48; 61 T.C.M. (CCH) 1759; T.C.M. (RIA) 91037;
January 30, 1991, Filed
Decisions will be entered in accordance with respondent's computations in docket Nos. 10234-79, 10236-79, 10238-79, 10240-79, 10242-79, 13246-80, 23476-81, 23479-81 and 16675-83.
Decisions…
2Cases cited12 opinions
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Bankers Pocahontas Coal Co. v. BurnetSupreme Court of the United States · 1932
- Woods v. CommissionerUnited States Tax Court · 1989
- Haft Trust v. CommissionerUnited States Tax Court · 1974
- Robin Haft Trust v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1975
7 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Terence J. Horn and Jean Horn v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Terence J. Horn and Jean HornCourt of Appeals for the D.C. Circuit · 1992
- Gardner v. CommissionerCourt of Appeals for the Second Circuit · 1992
- Gardner v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1992