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T.C. Memo. 2012305 UNITED STATES TAX COURT BRUCE GUNKLE AND SHERILYN S. GUNKLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 565011. Filed November 1, 2012. Scott W. Gross,.

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Tax Court Memorandum Decisions: Because Tax Court Memorandum Decisions are not reported in the Tax Court of the United States Reports, you must use the parallel citation to the respective CCH and RIA Reporters: CCH Tax Court Memorandum Decisions (T.C.M. (CCH)) and RIA Tax Court Memorandum Decisions (T.C.M. (RIA)).

To protect yourself against an unagreed assessment of tax or collection action, you should file a petition within the period set forth in the notice. You may also wish to contact the IRS about the status of your case.

Although both types of opinions can be cited as legal authority, Tax Court Opinions are considered binding precedent. Essentially, this means that they establish new law (or new guidance) on tax-related issues.

Regular decisions are officially published in the U.S. Tax Court Reports (T.C.), and for cases before 1942, in the U.S. Board of Tax Appeals Reports (B.T.A.). They are unofficially published in CCH's Tax Court Reporter and RIA's Tax Court Reports.

Tax Court Memorandum Decisions Basics "Generally, a Memorandum Opinion is issued in a regular case that does not involve a novel legal issue. A Memorandum Opinion addresses cases where the law is settled or factually driven. A Memorandum Opinion can be cited as legal authority, and the decision can be appealed. . . .

If you want to challenge the deficiency determination, file a petition with the U.S. Tax Court. File your tax return immediately (no later than 90 days from the date of the CP3219N) or accept our proposed assessment by signing and returning the Response form. Call us if you think you don't have to file.

A notice of deficiency is a legal determination by the IRS of a taxpayer's tax deficiency. It is an official written claim that a taxpayer owes additional income tax (and often interest on that amount, plus additional penalties).

You will get as fair and impartial a hearing in tax court as you would in any other federal court. After you file your petition, it will be at least six months until you are called for trial. While most small cases (see immediately below) are decided within one year, regular cases take much longer.

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Form Packages
Adoption
Bankruptcy
Contractors
Divorce
Home Sales
Employment
Identity Theft
Incorporation
Landlord Tenant
Living Trust
Name Change
Personal Planning
Small Business
Wills & Estates
Packages A-Z
Form Categories
Affidavits
Bankruptcy
Bill of Sale
Corporate - LLC
Divorce
Employment
Identity Theft
Internet Technology
Landlord Tenant
Living Wills
Name Change
Power of Attorney
Real Estate
Small Estates
Wills
All Forms
Forms A-Z
Form Library
Customer Service
Terms of Service
Content Takedown Policy
About Us
Blog
Affiliates
Contact Us
Privacy Notice
Delete My Account
Site Map
Industries
Forms in Spanish
Localized Forms
State-specific Forms
Forms Kit
Legal Guides
Real Estate Handbook
All Guides
Prepared for You
Notarize
Incorporation services
Our Customers
For Consumers
For Small Business
For Attorneys
Our Sites
US Legal Forms
USLegal
FormsPass
pdfFiller
signNow
airSlate workflows
DocHub
Instapage
Social Media
Call us now toll free:
+1 833 426 79 33
As seen in:
  • USA Today logo picture
  • CBC News logo picture
  • LA Times logo picture
  • The Washington Post logo picture
  • AP logo picture
  • Forbes logo picture
© Copyright 1997-2025
airSlate Legal Forms, Inc.
3720 Flowood Dr, Flowood, Mississippi 39232