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- 143 T.C. No. 11 UNITED STATES TAX COURT DENNIS E. BOHNER ...
Get 143 T.C. No. 11 UNITED STATES TAX COURT DENNIS E. BOHNER ...
Ined that P is ineligible for S corporation status in 2003 because its shareholder was a Roth individual retirement account (Roth IRA). As a consequence, R determined that P is taxable as a C corporation for 2003. Held: The Roth IRA is not an eligible S corporation shareholder. P is taxable as a C corporation for 2003. Steven R. Mather and Kenneth M. Barish, for petitioner. David W. Sorensen, for respondent. - 2 OPINION WHERRY, Judge: This case, which involves a petition for redetermination.
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Taproot FAQ
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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)).
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When referencing a CCH legal commentary from the CCH Intelliconnect database, provide: a description of the resource in square brackets. no date. This is because the date given on these commentaries is a reviewed date, which doesn't indicate that any information was changed, edited or included on the date of review.
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1) The Internal Revenue Code is codified at title 26 of the United States Code. Citations to the Internal Revenue Code often include neither the abbreviation for the U.S. Code ("U.S.C.") nor the pertinent title (title 26). They are replaced with "I.R.C.," an abbreviation for the Internal Revenue Code.
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The U.S. Tax Court is a specialized court that hears only federal tax cases at the trial level. Before 1943, the U.S. Tax Court was called the Board of Tax Appeals (BTA). Taxpayers appearing before the Tax Court are not required to pay the disputed tax amount before the case is heard (i.e., "deficiency procedure").
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