- Exhibit 35.11.1-159 Unlimited Transferee Liability: Taxes and Penalties — Several Years
- Exhibit 35.11.1-160 Limited Transferee Liability: One Tax and Single Transfer of Assets
- Exhibit 35.11.1-161 Limited Transferee Liability: Several Taxes, Penalties and Transfers of Assets
- Exhibit 35.11.1-162 Limited Transferee Liability: Deficiency and Unpaid Tax for One or More Years - Single Transfer of Assets
- Exhibit 35.11.1-163 Net Operating Losses: Tentative Net Operating Loss Not in Issue
- Exhibit 35.11.1-164 Net Operating Losses: Excessive Tentative Net Operating Loss Placed in Issue
- Exhibit 35.11.1-165 Net Operating Losses: Deficiency Prior to Net Operating Loss Carryback and Overpayment After Net Operating Loss Carryback
- Exhibit 35.11.1-166 Net Operating Losses: Overpayment Due Solely to Net Operating Loss Carryback — No Deficiency Prior to Carryback
- Exhibit 35.11.1-167 Net Operating Losses: Deficiency Both Before and After Net Operating Loss Carryback - No Carryback Claim Filed
- Exhibit 35.11.1-168 Net Operating Losses: Overpayment Before and After Allowance for Net Operating Loss Carryback
- Exhibit 35.11.1-169 Net Operating Losses: Deficiency Before and Overpayment After Net Operating Loss Carryback (Notice Sent under 6-Year Period of I.R.C. § 6501(e) and Overpayment Based on Carryback Claim)
- Exhibit 35.11.1-170 Motion to Stay Proceedings: Deficiency in Estate Tax (Extended Payment Under I.R.C. § 6161) - Stipulation
- Exhibit 35.11.1-171 Motion to Stay Proceedings: Deficiency in Estate Tax (Extended Payment Under I.R.C. § 6161) - Motion
- Exhibit 35.11.1-172 Collection Due Process Cases Decision Documents: Installment Agreement and Stipulated Decision
- Exhibit 35.11.1-173 Failure to Pay Addition to Tax for Returns Prepared Under I.R.C Section 6020(b)
- Exhibit 35.11.1-174 Innocent Spouse Decision Documents: I.R.C. Section 6015(e)(1)(A) Cases (Stand-Alone Cases) - Denial Section 6015(e)
- Exhibit 35.11.1-175 Innocent Spouse Decision Documents: I.R.C. Section 6015(e)(1)(A) Cases (Stand-Alone Cases) - Relief Granted in Full, No Overpayment
- Exhibit 35.11.1-176 Innocent Spouse Decision Documents: I.R.C. Section 6015(e)(1)(A) Cases (Stand-Alone Cases) — Relief Granted in Full, Overpayment
- Exhibit 35.11.1-177 Innocent Spouse Decision Documents: I.R.C. Section 6015(e)(1)(A) Cases (Stand-Alone Cases) — Partial Relief Granted, No Overpayment
- Exhibit 35.11.1-178 Innocent Spouse Decision Documents: I.R.C. Section 6015(e)(1)(A) Cases (Stand-Alone Cases) — Relief Denied in Full
- Exhibit 35.11.1-179 Innocent Spouse — Decision Documents in Deficiency Cases Involving Section 6015(For Stand-Alone Cases) — Relief Denied in Full
- Exhibit 35.11.1-180 Innocent Spouse Decision Documents: I.R.C. Section 6015(e)(1)(A) Cases (Stand-Alone Cases) Relief Granted in Full, No Overpayment
- Exhibit 35.11.1-181 Innocent Spouse Decision Documents: I.R.C. Section 6015(e)(1)(A) Cases (Stand-Alone Cases) — Relief Granted in Part, No Overpayment — Joint Petitioners
- Exhibit 35.11.1-182 Innocent Spouse Decision Documents: I.R.C. Section 6015(e)(1)(A) Cases (Stand-Alone Cases) — Relief Granted in Part, No Overpayment — One Petitioner
- Exhibit 35.11.1-183 Employment Tax: Decision document in settled section 7436 case — I.R.C. Section 530 in Favor of Petitioner
- Exhibit 35.11.1-184 Employment Tax: Decision document in settled I.R.C. Section 7436 case — Employment Status Decision in Favor of Petitioner
- Exhibit 35.11.1-185 Employement Tax: Decision document in settled I.R.C. Section 7436 case — Decision in Favor of Respondent
- Exhibit 35.11.1-186 Declaratory Judgement Cases: Retirement Plans
- Exhibit 35.11.1-187 Declaratory Judgement Cases: Exempt Organizations
- Exhibit 35.11.1-188 TEFRA: Rule 248(a) Decision per Settlement — Tabular Format - TEFRA Partnership
- Exhibit 35.11.1-189 TEFRA Partnership: Rule 248(b) Motion for Entry of Decision, Certificate and Decision — Tax Matters Partner is a Participating Partner
- Exhibit 35.11.1-190 TEFRA Partnership: Rule 248(b) Motion for Entry of Decision, Certificate and Decision — Tax Matters Partner is not a Participating Partner
- Exhibit 35.11.1-191 TEFRA Partnership: Rule 248(b) Motion for Entry of Decision, Certificate and Decision — Cash Out-of-Pocket Settlements
- Exhibit 35.11.1-192 TEFRA Partnership: Rule 248(b) Cash Out-of-pocket Settlements — Sample Letter to TMP and Partners
- Exhibit 35.11.1-193 TEFRA Partnership: Notice of objection to motion to participate out of time
- Exhibit 35.11.1-194 TEFRA Partnership: Motion to Appoint a Tax Matters Partner
- Exhibit 35.11.1-195 TEFRA Partnership: Penalty Only Affected Item -- Decision Document
- Exhibit 35.11.1-196 Compromise by the Attorney General
- Exhibit 35.11.1-197 Adjudication by Another Court Having Concurrent Jurisdiction With Tax Court: Another Court Disposed of All Issues Pending in Tax Court
- Exhibit 35.11.1-198 Adjudication by Another Court Having Concurrent Jurisdiction With Tax Court: All Issues Before the Tax Court Not Disposed of by Another Court
- Exhibit 35.11.1-199 Rule 155 Computation: Computation Face Sheet
- Exhibit 35.11.1-200 Rule 155 Computation: Proposed Decision
- Exhibit 35.11.1-201 Rule 155 Computation: Computation Statement — Tabular Form — Deficiency — Tax — Penalty — Husband and Wife — Joint and Several Liability — Separate Docket Numbers
- Exhibit 35.11.1-202 Rule 155 Computation: Computation Statement--Narrative Form — Deficiency — Tax — Penalty — Interim Assessment — Jeopardy Assessment — Overpayment
- Exhibit 35.11.1-203 Rule 155 Computation: Computation Statement — Overpayment of Tax and Penalty — Jeopardy Assessment
- Exhibit 35.11.1-204 Rule 155 Computation: Computation Statement — Transferee Liability — Computation for Transferor and/or Several Transferees Covering Duplication of Liability in Cases Before the Court
- Exhibit 35.11.1-205 Rule 155 Computation: Computation Statement — Carryback — Overpayment
- Exhibit 35.11.1-206 Rule 155 Computation: Computation Statement — Estate Tax — State Estate Tax
- Exhibit 35.11.1-207 Rule 155 Computation: Computation Statement — Short Form — No Change in Amount of Deficiency, or Computation Thereof, From That Shown in Statutory Notice — No Overpayment Involved
- Exhibit 35.11.1-208 Rule 155 Computation: Computation Statement — Portion of Overpayment Barred Notice sent under six-year period of section 6501(e)
- Exhibit 35.11.1-209 Award Data Sheet
- Exhibit 35.11.1-210 Payment Memorandum with Offset
- Exhibit 35.11.1-211 Payment Memorandum without Offset
| DECISION | ||
| Pursuant to agreement of the parties in this case, it is | ||
| ORDERED and DECIDED: That the following statement shows the liabilities due from the petitioner as transferee and trustee of assets of the [name of company], [city, state], transferor, for unpaid taxes and additions to the tax of the transferor for the taxable years ended [dates]: | ||
| Year Ended [date] | ||
| Income Tax | $ 10,000.00 | |
| Addition to tax [I.R.C. § 6663(a)] | 5,000.00 | |
| Liability | $ 15,000.00 | |
| plus interest as provided by law on $ [tax amount] of the liability from [date], and on $ [addition amount] of the liability from [date of notice and demand to transferor for penalty] to the date of payment. | ||
| Year Ended [date] | ||
| Income Tax | $ 45,000.00 | |
| Addition to tax [I.R.C. § 6663(a)] | 20,000.00 | |
| Liability | $ 65,000.00 | |
| plus interest as provided by law on $ [tax amount] of the liability from [date], and on $ [addition amount] of the liability from [date of notice and demand to transferor for penalty] to the date of payment. | ||
| Judge. | ||
| Entered: | ||
| * * * * * | ||
| It is stipulated that the Court may enter the foregoing decision. | ||
| It is further stipulated that, effective upon the entry of the decision by the Court, petitioner waives the restriction contained in I.R.C. § 6213(a) prohibiting assessment and collection of the liability (plus statutory interest) of the transferor for the taxable years ended [dates]. | ||
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| DECISION | ||
| Pursuant to agreement of the parties in this case, it is | ||
| ORDERED and DECIDED: That the following statement shows the liabilities due from the petitioner as transferee of assets of [entity name], [city, state], transferor, for unpaid income taxes and additions to the tax under the provisions of I.R.C. § 6663(a), of the transferor for the taxable years [year 1] and [year 2]: | ||
| [year 1] | ||
| Income Tax | $ 30,000.00 | |
| Addition to tax (I.R.C. § 6663(a)) | 10,000.00 | |
| Liability | $ 40,000.00 | |
| plus interest on the above liability as provided by law from [date of transfer] to the date of payment. | ||
| [year 2] | ||
| Income Tax | $240,000.00 | |
| Addition to tax (I.R.C. § 6663(a)) | 120,000.00 | |
| Liability | $360,000.00 | |
| plus interest on the above liability as provided by law as follows: On $[amount 1] from [first date of transfer]; on $[amount 2] from [second date of transfer]; and on $[amount 3] from [third date of transfer] to date of payment. | ||
| Judge. | ||
| Entered: | ||
| * * * * * | ||
| It is stipulated that the Court may enter the foregoing decision. | ||
| It is further stipulated that, effective upon the entry of the decision by the Court, petitioner waives the restriction contained in I.R.C. § 62 13(a) prohibiting assessment and collection of the liability (plus statutory interest) until the decision of the Tax Court has become final. | ||
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| STIPULATION | ||
| It is hereby stipulated that the following statement shows the petitioner’s income tax liability for the taxable year [year 1]: | ||
| Tax liability computed without allowance for net operating loss carryback from [year 2] to [year 1]: | $ 4,000.00 | |
| Tax assessed and paid ([date]): | $ 4,000.00 | |
| Less tentative carryback allowance made on [date]: | 3,500.00 | |
| Net tax assessed and paid: | $ 500.00 | |
| Deficiency without allowance for net operating loss carryback: | $ 4,000.00 | |
| Reduction in liability due to net operating loss carryback | 1,000.00 | |
| Deficiency in income tax after allowance for net operating loss carryback: | $ 3,000.00 | |
| It is further stipulated that, effective upon the entry of the decision by the Court, petitioner waives the restriction contained in I.R.C. § 6213(a) prohibiting assessment and collection of the deficiency until the decision of the Tax Court has become final. | ||
| DECISION | ||
| Pursuant to the stipulation of the parties filed in the above-entitled case, and incorporating herein the facts so stipulated as the findings of the Court, it is | ||
| ORDERED AND DECIDED: That there is a deficiency in income tax due from the petitioner for the taxable year [year 1] in the amount of $ [amount] | ||
| Judge. : | ||
| Entered | ||
| * * * * * | ||
| It is stipulated that the Court may enter the foregoing decision. | ||
| STIPULATION | ||||
| It is hereby stipulated that the following statement shows the petitioner’s income tax liabilities for the taxable year [year 1]: | ||||
| Tax liability, computed without allowance for net operating loss carryback from [year 2] to [year 1] | $ 100,000.00 | |||
| Tax assessed and paid | 80,000.00 | |||
| Deficiency, without allowance for net operating loss carryback | $ 20,000.00 | |||
| Tax paid | $ 80,000.00 | |||
| Payments: | ||||
| March 15, 2000 June 14, 2000 September 15, 2000 December 15, 2000 |
$ 20,000.00 20,000.00 20,000.00 20,000.00 |
|||
| Total payments | $ 80,000.00 | |||
| Tax liability, after allowance for net operating loss carryback | 70,000.00 | |||
| Overpayment | $ 10,000.00 | |||
I.R.C. §§ 6512(b)(2)(B) and 6511(d)(2)
Return filed [date]
No
claim filed
No agreements executed
Deficiency notice mailed [date]
| DECISION | |
| Pursuant to the stipulation of the parties in the aboveentitled case, and incorporating herein the facts stipulated by the parties as the findings of the Court, it is | |
| ORDERED and DECIDED: That there is an overpayment in income tax for the taxable year [year 1] in the amount of $10,000.00, which amount was paid on [date], and for which amount a claim for refund could have been filed under the provisions of I.R.C. § 6511(d)(2) on [date 2], the date of the mailing of the notice of deficiency. | |
| Judge. | |
| Entered: | |
| * * * * * | |
| It is hereby stipulated that the Court may enter the foregoing decision in the above-entitled case in accordance with the stipulation of the parties submitted herewith. | |
| STIPULATION | ||||||
| It is hereby stipulated that the following statement shows the petitioner’s income tax liability for the taxable year ended [date]: | ||||||
| Net tax assessed and paid | $ 1,000,000.00 | |||||
| Payments: | ||||||
| July 15, 2000 October 14, 2000 January 14, 2000 April 15, 2000 |
$ 300,000.00 300,000.00 300,000.00 300,000.00 |
|||||
| Total payments | $ 1,200,000.00 | |||||
| Less: Allowance | ||||||
| August, 2000 | 200,000.00 | |||||
| Net payments | $ 1,000,000.00 | |||||
| Tax liability, after allowance for net operating loss carryback from the fiscal year ended April 30, 2000 | 900,000.00 | |||||
| Overpayment | $ 100,000.00 | |||||
I.R.C. §§ 6512(b)(3)(B) and 6511(d)(2)
Return filed [date]
No
claim filed
No agreements executed
Deficiency notice mailed [date]
| DECISION | |
| Pursuant to the stipulation of the parties filed in the above-entitled case, and incorporating herein the facts stipulated by the parties as the findings of the Court, it is | |
| ORDERED and DECIDED: That there is an overpayment in income tax for the taxable year ended [date], which amount was paid on [date 2], in the amount of $ [amount], and for which amount a claim for refund could have been filed under the provisions of I.R.C. § 6511(d) (2) on [date 3], the date of the mailing of the notice of deficiency. | |
| Judge. | |
| Entered: | |
| * * * * * | |
| It is hereby stipulated that the Court may enter the foregoing decision in the above-entitled case in accordance with the stipulation of the parties submitted herewith. | |
| STIPULATION | ||
| It is hereby stipulated that the following statement shows the petitioner’s income tax liabilities for the taxable years [year 1] and [year 2]: | ||
| [year 1] | ||
| Tax liability, computed without allowance for net operating loss carryback from [year 2] to [year 1] | $ 250,000.00 | |
| Tax assessed and paid | 200,000.00 | |
| Deficiency, without allowance for net operating loss carryback | $ 50,000.00 | |
| Reduction in liability due to net operating loss carryback | 20,000.00 | |
| Deficiency, after allowance for net operating loss carryback | $ 30,000.00 | |
| No net operating loss carryback claim filed | ||
| [year 2] | ||
| Tax liability, computed without allowance for net operating loss carryback from [year 2] to [year 1] | $ 300,000.00 | |
| Tax assessed and paid | 100,000.00 | |
| Deficiency, without allowance for net operating loss carryback | $ 200,000.00 | |
| Reduction in liability due to net operating loss carryback | 100,000.00 | |
| Deficiency, after allowance for net operating loss carryback | $ 100,000.00 | |
| No net operating loss carryback claim filed | ||
| It is further stipulated that, effective upon entry of this decision by the Court, petitioner waives the restriction contained in I.R.C. § 6213(a) prohibiting assessment of the deficiency (plus statutory interest) until the decision of the Tax Court has become final. | ||
| DECISION | |
| Pursuant to the stipulation of the parties filed in the above-entitled case, and incorporating herein the facts stipulated by the parties as the findings of the Court, it is | |
| ORDERED and DECIDED: That there are deficiencies in income taxes due from the petitioner for the taxable years [year 1] and [year 2] in the amounts of $ [amount 1] and $ [amount 2], respectively. | |
| Judge. | |
| Entered: | |
| * * * * * | |
| It is hereby stipulated that the Court may enter the foregoing decision in the above-entitled case in accordance with the stipulation of the parties submitted herewith. | |
| STIPULATION | |||||
| It is hereby stipulated that the following statement shows the petitioner’s income tax liabilities for the taxable year [year 1]: | |||||
| Tax assessed and paid | $ 400,000.00 | ||||
| Payments: | |||||
| March 15, 2000 June 15, 2000 September 15, 2000 December 15, 2000 |
$ 100,000.00 100,000.00 100,000.00 100,000.00 |
||||
| Total payments | $ 400,000.00 | ||||
| Tax liability, after allowance for net operating loss carryback from [year 2] to [year 1] | 300,000.00 | ||||
| Overpayment | $ 100,000.00 | ||||
| I.R.C. §§ 6512(b)(3)(B) and
6511(d)(2) Return filed [date] No claim filed No agreements executed Deficiency notice mailed [date] |
|||||
| * * * * * | |||||
| Overpayment, due to net operating loss carryback | $ 50,000.00 | ||||
| Overpayment, before allowance for net operating loss carryback | 50,000.00 | ||||
| Total overpayment, as shown above | $ 100,000.00 | ||||
| DECISION | |
| Pursuant to the stipulation of the parties filed in the above-entitled case, and incorporating herein the facts stipulated by the parties as the findings of the Court, it is | |
| ORDERED and DECIDED: That there is an overpayment in income tax for the taxable year [year 1] in the amount of $ [amount], which amount was paid on [date], and for which amount a claim for refund could have been filed under the provisions of I.R.C. § 6511(d)(2), on [date 2], the date of the mailing of the notice of deficiency. | |
| Judge. | |
| Entered: | |
| * * * * * | |
| It is hereby stipulated that the Court may enter the foregoing decision in the above-entitled case in accordance with the stipulation of the parties submitted herewith. | |
| STIPULATION | |||||
| It is hereby stipulated that the following statement shows petitioner’s income tax liability for the taxable year [year 1]: | |||||
| Tax liability, computed without allowance for net operating loss carryback from [year 2] to [year 1] | $ 100,000.00 | ||||
| Tax assessed and paid | 50,000.00 | ||||
| Deficiency, without allowance for net operating loss carryback | $ 50,000.00 | ||||
| Tax paid | $ 50,000.00 | ||||
| Payments: | |||||
| April 15, 2000 June 15, 2000 September 14, 2000 December 14, 2000 |
$ 12,500.00 12,500.00 12,500.00 12,500.00 |
||||
| Total payments | $ 50,000.00 | ||||
| Tax liability, after allowance for net operating loss carryback | 48,000.00 | ||||
| Overpayment | $ 2,000.00 | ||||
| I.R.C. §§ 6512(b)(3)(C) and
6511(d)(2) Return filed [date] Claim for net operating loss carryback filed [date] No agreement executed Deficiency notice mailed [date] |
|||||
| It is further stipulated that, effective upon the entry of this decision by the Court, petitioner waives the restriction contained in I.R.C. § 6213(a) prohibiting assessment and collection of the deficiency, plus statutory interest, until the decision of the Tax Court has become final. | |||||
| DECISION | |
| Pursuant to the stipulation of the parties filed in the above-entitled case, and incorporating herein the facts stipulated by the parties as the findings of the Court, it is | |
| ORDERED and DECIDED: That there is an overpayment in income tax for the taxable year [year 1] in the amount of $ [amount], which amount was paid on [date], and for which amount a claim for refund was filed on [date], which was within the period provided by I.R.C. § 6511(d) (2), and which claim had not been disallowed before the date of the mailing of the notice of deficiency. | |
| Judge. | |
| Entered: | |
| * * * * * | |
| It is hereby stipulated that the Court may enter the foregoing decision in the above-entitled case in accordance with the stipulation of the parties submitted herewith. | |
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