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The Pekar case is a great case to cite to Revenue Agents. Commissions, 113 TC 157, 166 (1999), which states, "Each tax year stands by itself, and the Commissioner is not bound by his treatment of an item for a previous year." In court, the taxpayer argued the IRS, "allowed substantially similar depreciation deductions for prior years and that it would therefore be logically preposterous to deny the deductions for 2011." IRS, TC Memo 2016-148, the taxpayer took $12,332 of depreciation. One often question I get is if an adjustment in one year will affect future tax returns. Even though the money goes to the same place, an exception only applies to IRS levies on these accounts. This is a good place to remind people that if the IRS wishes a client to make a distribution out of an IRA to pay past due taxes, its often better to request the IRS to levy the account so the taxpayer will not need to pay the 10% penalty. The contributions must be made 30 days after the event above stops occurring. Under the Rev Proc, they can fail to miss the 60 day window due to: an error committed by the financial institution either getting or sending the contribution, a misplaced check, deposit into an account that was thought to be an eligible retirement plan, client's principal residence was damaged, a death in the family, a serious illness in the family, incarceration, restrictions imposed by foreign country, postal errors, IRS levy that is returned, or taxpayer made a reasonable effort but the contribution was delayed by the financial institution. In Rev Proc 2016-47, the IRS has made it much easier for people seeking a waiver for missing their 60 days required to make an IRA rollover contribution.
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Under competent representation, the taxpayer could have 1) avoided Tax Court all together and 2) reduced the amount of tax due through proper submissions of deductions, credits and exemptions. This is a good case to point out to potential clients. The failure to respond and support any deductions was also upheld. Since the taxpayer failed to assign error in his petition that the income was not his, the income was proven to be the taxpayers.
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Under Rule 90(c), that means all matters were deemed admitted. The IRS requested the taxpayer respond to admissions of 1) having received the income, 2) having failed to file a return, 3) provide documents for any deductions, credits, and exemptions he would be entitled, and 4) show anything that he is not liable for any penalties. I would like to file my own return for 2012." "I had a hard drive failure and lost data. The taxpayer filed in Tax Court challenging the SFR on the grounds of, The IRS properly filed an SFR for the taxpayer, which allowed the standard deduction and one personal exemption. Barrion did not file his 2012 tax return. There was an interesting Tax Court case, Barrion v.