Procedural Issues
Appeals

Perfection of Imperfect CDP Appeals

On Latin Nerdery and Perfection of Imperfect CDP Appeals If you have read many of the posts on Briefly Taxing, it should come as no surprise to you that I was a Latin nerd in high school…and college…and at present. The truth of the matter is that I competed nationally, my specialty being Greek mythology. My sophomore year of high school I missed a single question on the national exam. One question. My Latin teacher,

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Scott St. Amand August 12, 2021
Taxing, Briefly
30-Day Letter

The IRS Examination Process – Taxing, Briefly

Like Ten Thousand Spoons When All You Need is a Knife Do you feel like you are cursed to forever draw the short straw in life? Is Alanis Morrisette’s Ironic more of a personal anthem than an indictment of the Canadian educational system’s failure to properly differentiate between irony and unfortunate occurrences?  What does this have to do with the IRS examination process?  All in good time… In this post, we will assume that, in addition

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Scott St. Amand May 25, 2021
Procedural Issues
Appeals Division

Dang v. Commissioner
T.C. Memo. 2020-150

On November 9, 2020, the Tax Court issued a Memorandum Opinion in the case Dang v. Commissioner (T.C. Memo. 2020-150). The primary issue before the court in Dang v. Commissioner was whether the petitioners incurred “reasonable administrative costs” under IRC § 7430 and whether the petitioners are entitled to an award of reasonable litigation costs.

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Scott St. Amand November 9, 2020
Procedural Issues
Abuse of Discretion

Dodson v. Commissioner
T.C. Memo. 2020-106

On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Dodson v. Commissioner (T.C. Memo. 2020-106). The primary issue before the court in Dodson v. Commissioner was whether the IRS abused its discretion by denying the petitioners’ proposed installment agreement. Petitioners in Dodson v. Commissioner Not Paragons of Tax Compliance The petitioners are in the real estate business, earning income from real estate brokerage and from rental of properties that

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Scott St. Amand July 9, 2020
Procedural Issues
Appeals Division

Cosio v. Commissioner
T.C. Memo. 2020-90

On June 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Cosio v. Commissioner (T.C. Memo. 2020-90). The primary issue before the court in Cosio v. Commissioner was whether the petitioner received a reasonable opportunity to present evidence pertaining to his tax liability for 2015, when all notices sent to the petitioner referenced his 2012 liability and his right to a hearing thereupon. Background to Cosio v. Commissioner From the limited

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Scott St. Amand June 18, 2020
Procedural Issues
Abuse of Discretion

Kirkley v. Commissioner
T.C. Memo. 2020-57

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Kirkley v. Commissioner (T.C. Memo. 2020-57). The primary issue before the court in Kirkley v. Commissioner was whether the IRS’s determination that petitioners must liquidate all of their property, including their residence, as a condition for the IRS’s acceptance of an installment agreement, was a (rather egregious) abuse of discretion. Statement of Facts in Kirkley v. Commissioner The common perception

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Scott St. Amand May 13, 2020
Income Tax Issues
Appeals Division

Etoty v. Commissioner
T.C. Memo. 2020-49

On April 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Etoty v. Commissioner (T.C. Memo. 2020-49). The issue before the court in Etoty v. Commissioner was whether the levy on the petitioner’s New York State tax refund should not [sic] be sustained. A Lesson in Etoty v. Commissioner to Judge Lauber on When “Less is More” Should be Ignored Petitioner filed a timely Federal income tax return for 2008. Because

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Scott St. Amand April 20, 2020
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Perfection of Imperfect CDP Appeals

On Latin Nerdery and Perfection of Imperfect CDP Appeals If you have read many of the posts on Briefly Taxing, it should come as no surprise to you that I was a Latin nerd in high school…and college…and at present. The truth of the matter is that I competed nationally,

Read More »
Scott St. Amand August 12, 2021

The IRS Examination Process – Taxing, Briefly

Like Ten Thousand Spoons When All You Need is a Knife Do you feel like you are cursed to forever draw the short straw in life? Is Alanis Morrisette’s Ironic more of a personal anthem than an indictment of the Canadian educational system’s failure to properly differentiate between irony and

Read More »
Scott St. Amand May 25, 2021

Dang v. Commissioner
T.C. Memo. 2020-150

On November 9, 2020, the Tax Court issued a Memorandum Opinion in the case Dang v. Commissioner (T.C. Memo. 2020-150). The primary issue before the court in Dang v. Commissioner was whether the petitioners incurred “reasonable administrative costs” under IRC § 7430 and whether the petitioners are entitled to an

Read More »
Scott St. Amand November 9, 2020

Dodson v. Commissioner
T.C. Memo. 2020-106

On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Dodson v. Commissioner (T.C. Memo. 2020-106). The primary issue before the court in Dodson v. Commissioner was whether the IRS abused its discretion by denying the petitioners’ proposed installment agreement. Petitioners in Dodson v. Commissioner

Read More »
Scott St. Amand July 9, 2020

Cosio v. Commissioner
T.C. Memo. 2020-90

On June 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Cosio v. Commissioner (T.C. Memo. 2020-90). The primary issue before the court in Cosio v. Commissioner was whether the petitioner received a reasonable opportunity to present evidence pertaining to his tax liability for 2015, when

Read More »
Scott St. Amand June 18, 2020

Kirkley v. Commissioner
T.C. Memo. 2020-57

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Kirkley v. Commissioner (T.C. Memo. 2020-57). The primary issue before the court in Kirkley v. Commissioner was whether the IRS’s determination that petitioners must liquidate all of their property, including their residence, as a condition

Read More »
Scott St. Amand May 13, 2020

Etoty v. Commissioner
T.C. Memo. 2020-49

On April 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Etoty v. Commissioner (T.C. Memo. 2020-49). The issue before the court in Etoty v. Commissioner was whether the levy on the petitioner’s New York State tax refund should not [sic] be sustained. A Lesson in

Read More »
Scott St. Amand April 20, 2020