Treece Financial Services Group v. Commissioner
158 T.C. No. 6

On April 19, 2022, the Tax Court issued the full opinion in Treece Financial Services Group v. Commissioner (158 T.C. No. 6). The primary issue presented in Treece Financial Services Group v. Commissioner was whether the Tax Court had jurisdiction to determine whether Voluntary Classification Settlement Program (VCSP) entered into computation of taxes owed by the taxpayer. Held: Indeed, it did. Treece Financial Services Group v. Commissioner in a Nutshell Treece Financial Services Group, a corporation, petitioned for review of a notice of employment tax determination under IRC § 7436. The parties agree that the IRS properly determined that Mr. Treece is an employee of Treece Financial Services Group, but they dispute the proper amount of employment tax under that determination. Treece Financial Services Group asserts that the amount should be computed using the IRS’s Announcement 2012-45, and that it is entitled to use the Voluntary Classification Settlement Program (VCSP)…

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