The Korean American Senior Mutual Assoc. Inc. v. Commissioner
T.C. Memo. 2020-129

On September 9, 2020, the Tax Court issued a Memorandum Opinion in the case of The Korean American Senior Mutual Assoc. Inc. v. Commissioner (T.C. Memo. 2020-129). The primary issue before the court in Korean-American was whether The Korean-American Senior Mutual Association, Inc. (KASMA) was operated exclusively for one or more exempt purposes as set forth in IRC § 501(c)(3). Background to The Korean American Senior Mutual Assoc. Inc. v. Commissioner The Korean-American Senior Mutual Association, Inc. (KASMA) was founded in 1996 informed for four purposes: (1) to provide burial benefits and assistance to the surviving families of deceased; (2) to provide information to senior citizens in regard to their burial concerns and general welfare; (3) to provide organized activities for senior citizens to enhance their effective use of free time and friendship; and (4) to provide annual scholarships to needy, promising students. In August 1998, the IRS sent a…

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Fowler v. Commissioner
155 T.C. No. 7

On September 9, 2020, the Tax Court issued its opinion in Fowler v. Commissioner (155 T.C. No. 7). The primary issue presented in Fowler v. Commissioner was whether the electronic filing of a tax return which was rejected by the IRS’s software for failure to include and Identity Protection Personal Identification Number (IP PIN) triggered the three-year limitations period to assess tax pursuant to IRC § 6501(a). Background to Fowler v. Commissioner The petitioner timely applied for an extension to file his 2013 return until October 15, 2014. The petitioner submitted his 2013 Form 1042 the IRS on October 15, 2014; October 28, 2014; and April 30, 2015. Each 2013 Form 1040 contain the same information to calculate tax liability; however, the IRS accepted only the final submission. The IRS rejected the first submission which was e-filed for failure to provide a valid Identity Protection Personal Identification Number (IP PIN)…

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