Kallich v. Comm'r of Internal Revenue

23 Citing cases

  1. Sumner v. Comm'r of Internal Revenue

    No. 9431-23S (U.S.T.C. Apr. 22, 2024)

    For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).

  2. Olivas v. Comm'r of Internal Revenue

    No. 6188-23 (U.S.T.C. Jul. 7, 2023)

    However, for the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. I.R.C. sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).

  3. Hammer v. Comm'r of Internal Revenue

    No. 27486-22S (U.S.T.C. Apr. 3, 2023)

    Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).

  4. Walker v. Comm'r of Internal Revenue

    No. 3159-22S (U.S.T.C. Mar. 3, 2023)

    For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987). On March 1, 2023, respondent filed a Response to Order to Show Cause.

  5. Seigerman v. Comm'r of Internal Revenue

    No. 15858-22S (U.S.T.C. Oct. 24, 2022)

    For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. I.R.C. sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987). The "amount of the deficiency placed in dispute" includes the deficiency and any additions to tax and penalties determined by respondent in the notice of deficiency upon which the case is based, I.R.C. sec. 7463(e), less any concessions made by petitioners in the petition. Because, at this juncture, the amount of the deficiency placed in dispute exceeds the $50,000 jurisdictional maximum for small tax cases, it is

  6. Chisholm v. Comm'r of Internal Revenue

    No. 18376-22S (U.S.T.C. Oct. 19, 2022)

    Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).

  7. Owens v. Comm'r of Internal Revenue

    No. 20914-22S (U.S.T.C. Oct. 13, 2022)

    For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. See I.R.C. ยง 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 678-681 (1987).

  8. McCormick v. Comm'r of Internal Revenue

    No. 12266-22S (U.S.T.C. Aug. 1, 2022)

    For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).

  9. Sparkman v. Comm'r of Internal Revenue

    No. 4628-22S (U.S.T.C. May. 19, 2022)

    For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. I.R.C. sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).

  10. Grant v. Comm'r of Internal Revenue

    No. 1821-22S (U.S.T.C. Apr. 25, 2022)

    For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987). On March 30, 2022, petitioners filed a Reply to the Court's order to show cause.