Legal Opinion
Philip N. Rose & Leanna Rose v. Commissioner
United States Tax Court
Decided June 13, 2019No. 21436-15Unpublished
1Opinion of the Court
T.C. Memo. 2019-73
UNITED STATES TAX COURT PHILIP N. ROSE AND LEANNA ROSE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21436-15. Filed June 13, 2019. David C. Dodge, for petitioner. Kimberly A. Trujillo, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PUGH, Judge: In a notice of deficiency dated May 26, 2015, respondent determined the following deficiencies and penalties:1 1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the years in issue. Rule references are to the Tax Court Rules of…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- HIGBEE v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
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