On January 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Reynolds v. Commissioner (T.C. Memo. 2021-10). The issue presented in Reynolds v. Commissioner was whether the IRS possessed the collection authority under IRC § 6201(a)(4) to undertake administrative collection action to collect restitution-based assessments (RBAs). Note on “Precedent” to Reynolds v. Commissioner It should be noted that the argument the petitioner made in Reynolds was “squarely rejected” in the case of Carpenter v. Commissioner, 152 T.C. 202, 219 (2019), aff’d 788 F.App’x 187 (4th Cir. 2019)…but the petitioner “invited” the Tax Court to “reconsider” the holding in Carpenter.  Tax Court Judge Thorton, not one to mince words, states simply “We decline the invitation.” Background to Reynolds v. Commissioner This is the cautionary tale of Dana Ray Reynolds, who, according to the opinion, “developed strategies to use corporations to conceal assets and evade income tax.” In…