EFTA00730479Set 9
2010-11-0111p5,330w
doing business there to receive
substantial benefits, including reduced tax rates.
In its notice of deficiency, the IRS said that Appleton failed to meet the requirements of
section ... Islands territorial
income tax returns and on November 25, 2009, issued petitioner a notice of deficiency,
determining the following Federal income tax deficiencies and additions to tax:
Additions ... dividends, and a 100-percent exemption on gross receipts taxes.
III. Respondent's Notice of Deficiency
Attached to respondent's notice of deficiency was a Form 4549-A, Income
https://www.justice.gov/epstein/files/DataSet%209/EFTA00730479.pdf
EFTA00598056Set 9
2011-02-1415p11,023w
cash or by
providing designated amounts of charitable services.
R issued a notice of deficiency for 1998 disallowing the charitable contribution deduction claimed,
requiring the inclusion in Ps' gross income ... petitioners' counsel in this proceeding.
On September 16, 2003, respondent issued petitioners a notice of deficiency for 1998 disallowing their
claimed charitable contribution deduction for the transfers of stocks ... letter issued in May 2002 and formally did so in a notice of deficiency issued on September 16, 2003.
No distributions for student loans were made from petitioner's Foundation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598056.pdf
EFTA01946229Set 10
2012-06-139p6,046w
stipulated reductions in his deficiency determinations due to miscalculations made
in his notices of deficiency. Above, we reflect respondent's deficiencies as recalculated by
respondent.
3 Unless otherwise indicated ... charge any income to
GSN or TerSen, and did not issue notices of deficiency to GSN or TerSen. The $710,376 in compensation
income respondent determined was charged ... number of procedural arguments that we briefly address. Petitioners contend that respondent's notices
of deficiency were vague and inadequate because they did not reference a specific Code section
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01946229.pdf
EFTA00598102Set 9
2007-12-1731p20,075w
April 15, 2005, respondent sent notices of deficiency to Rhett and Alice for their
1998, 1999, 2000, and 2001 tax years. On March 25, 2005, respondent sent a notice ... April 15,
2005, respondent sent notices of deficiency to Rance and LaRhea for their 1998, 1999, 2000, and 2001 tax years.
Petitioners J. Zane Smith (Zane) and Shannon R. Creese ... April 15, 2005, respondent sent notices of deficiency to Zane and Shannon for their 1998, 1999, 2000, and 2001 tax
years.
Rance and LaRhea Smith are the parents of Rhett
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598102.pdf
EFTA00598897Set 9
2017-05-0520p6,129w
proceedings.
If you have any affected items subject to deficiency procedures, a separate notice of deficiency will be sent to
you.
If you write, please include your telephone number ... proceedings.
If you have any affected items subject to deficiency procedures, a separate notice of deficiency will be sent to
you.
If you write, please include your telephone number
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598897.pdf
EFTA00598877Set 9
2017-05-0520p6,069w
proceedings.
If you have any affected items subject to deficiency procedures, a separate notice of deficiency will be sent to
you.
If you write, please include your telephone number ... proceedings.
If you have any affected items subject to deficiency procedures, a separate notice of deficiency will be sent to
you.
If you write, please include your telephone number
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598877.pdf
EFTA00598139Set 9
2011-06-168p4,874w
Cohen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARIS, Judge: By separate notices of deficiency dated April 9, 2003, respondent determined a deficiency ... parties according to the value stated in the appraisal.
By separate notices of deficiency, the Commissioner determined a deficiency in the Federal gift tax of each of the
McCords
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598139.pdf
EFTA00598147Set 9
2011-06-158p5,152w
Cohen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
PARIS, Judge: By separate notices of deficiency dated April 9, 2003, respondent determined a deficiency ... parties according to the value stated in the appraisal.
By separate notices of deficiency, the Commissioner determined a deficiency in the Federal gift tax of each of the
McCords
https://www.justice.gov/epstein/files/DataSet%209/EFTA00598147.pdf
EFTA01103666Set 9
20p12,308w
also waived reliance on sec. 2038, which was
refernd to in the notice of deficiency.
4 Sec. 20.2036-1(aXii), Estate Tax Regs., provides:
An interest or right is treated ... Gilman's authority or anything.
13 Beginning in 1955, the year before the notice of deficiency in that case was issued, and continuing through 1964, decedent's salary
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103666.pdf
EFTA00643178Set 9
2015-12-314p1,586w
market value of the Dubuffet to be $500,000. For
purposes of the notice of deficiency, the IRS valued the Dubuffet at $750,000, as of the date
of death ... expert valued the painting at $10 million, $3 million lower than in its notice of
deficiency.
The Estate argued that the sale was a "fluke" and should be ignored. Furthermore
https://www.justice.gov/epstein/files/DataSet%209/EFTA00643178.pdf
EFTA01459199Set 10
2010-02-021p658w
market value of the Dubuffet to be $500,000. For purposes of the notice of deficiency, the IRS
valued the Dubuffet at $750,000, as of the date of death ... expert valued the painting at $10 million, $3 million
lower than in its notice of deficiency.
The Estate argued that the sale was a "fluke" and should be ignored. Furthermore
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01459199.pdf