Taxing, Briefly
30-Day Letter

Taxing, Briefly: The IRS Examination Process

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? In this post, we will assume that, in addition to the black fly in your chardonnay, you were greeted with a care package

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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 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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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 was whether the IRS abused its discretion by denying the petitioners’ proposed installment agreement.

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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 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.

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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 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.

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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 was whether the levy on the petitioner’s New York State tax refund should not [sic] be sustained.

Read More »
Abuse of Discretion

Hommel v. Commissioner (T.C. Memo. 2020-4)

On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The real issue, however, was how close Judge Holmes could get to calling the petitioner a #^&%$ idiot without actually doing so.

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Taxing, Briefly: The IRS Examination Process

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 »

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 was whether the petitioners incurred “reasonable administrative costs” under IRC § 7430 and whether the petitioners are entitled to an award of

Read More »

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 was whether the IRS abused its discretion by denying the petitioners’ proposed installment agreement.

Read More »

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 was whether the petitioner received a reasonable opportunity to present evidence pertaining to his tax liability for 2015, when all notices

Read More »

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 was whether the IRS’s determination that petitioners must liquidate all of their property, including their residence, as a condition for the

Read More »

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 was whether the levy on the petitioner’s New York State tax refund should not [sic] be sustained.

Read More »

Hommel v. Commissioner (T.C. Memo. 2020-4)

On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The real issue,

Read More »