Porter v. Comm'r
United States Tax Court
P applied for relief from joint and several liability for additional tax under sec. 72(t), I.R.C., related to a distribution her husband received from his individual retirement account. R denied P's application for relief. P petitioned this Court to seek our determination whether she is entitled to relief under sec. 6015(f), I.R.C.
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P applied for relief from joint and several liability for additional tax under sec. 72(t), I.R.C., related to a distribution her husband received from his individual retirement account. R denied P's application for relief. P petitioned this Court to seek our determination whether she is entitled to relief under sec. 6015(f), I.R.C. Held: In determining whether P is entitled to equitable relief under sec. 6015(f), I.R.C., we apply a de novo standard of review, not an abuse of discretion standard of review. Held, further: P is entitled to equitable relief under sec. 6015(f), I.R.C. Held,…
1Opinion of the Court
SUZANNE L. PORTER A.K.A. SUZANNE L. HOLMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Porter v. Comm'r
No. 13558-06
United States Tax Court
132 T.C. 203; 2009 U.S. Tax Ct. LEXIS 26; 132 T.C. No. 11;
April 23, 2009, Filed
Porter v. Commissioner, 130 T.C. 115, 2008 U.S. Tax Ct. LEXIS 10 (2008)
The court entered a decision for the taxpayer.
P applied for relief from joint and several liability for additional tax under sec. 72(t), I.R.C., related to a distribution her husband received from his individual retirement account. R denied P's application for relief. P petitioned this Court to…
Also in this document: Concurrence; Dissent · Wells; Dissent · Gustafson.
2Cases cited77 opinions
- Firestone Tire & Rubber Co. v. BruchSupreme Court of the United States · 1989
- 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
- Goza v. CommissionerUnited States Tax Court · 2000
- Jama v. Immigration and Customs EnforcementSupreme Court of the United States · 2005
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