144 T.C. No. 17 UNITED STATES TAX COURT JEFFREY T ... - ustaxcourt 2025

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Find a Case Go to the DAWSON homepage. To search for a case by Docket Number, you must include the dash in the Docket Number (e.g., 123-18). You may, but do not have to, include the letter suffix (S, L, SL, R, X, D, or P) of the Docket Number to find a case.
Trials are conducted before one judge, without a jury, and taxpayers are permitted to represent themselves if they desire. Taxpayers may be represented by practitioners admitted to the bar of the Tax Court. Most cases are settled by mutual agreement without trial.
Locate a federal court case by using the Public Access to Court Electronic Records (PACER) or by visiting the Clerks Office of the courthouse where the case was filed.
Pursuant to 26 USC Section 7461(a), all reports of the Tax Court and all evidence received by the Tax Court, including a transcript of the record of the hearings, generally are public records open to inspection by the public.
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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The mission of the United States Tax Court is to provide a national forum for the expeditious resolution of disputes between taxpayers and the Internal Revenue Service; for careful consideration of the merits of each case; and to ensure a uniform interpretation of the Internal Revenue Code.
Regular decisions are officially published in the Reports of the United States Tax Court, and for cases before 1942, in the U.S. Board of Tax Appeals Reports (B.T.A.). They are unofficially published in CCHs Tax Court Reporter and RIAs Tax Court Reports.
Citing the investor control doctrine and other principles, the Internal Revenue Service (IRS or respondent) concluded that petitioner retained sufficient control and incidents of ownership over the assets in the separate accounts to be treated as their owner for Federal income tax purposes.

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