Income Tax Issues
Alter Ego Liability

Successor Liability in a Purchase of Corporate Assets

As a tax controversy lawyer, most of your clients come to you in quite a predicament with the IRS, rather than coming to you to avoid said predicament. Such is the case when Cousin Elmer comes to visit you one dismal winter day. You may remember Elmer from our article on FBARs, but if not, Cousin Elmer has seven and a half fingers from trying, rather unsuccessfully, to eradicate his attic’s squirrel population through the

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Scott St. Amand April 29, 2021
Procedural Issues
Assessment

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

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Scott St. Amand September 9, 2020
Procedural Issues
Abatement of Interest

Goldberg v. Commissioner
T.C. Memo. 2020-38

On April 2, 2020, the Tax Court issued a 163-page Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2020-38). The issues properly before the court in Goldberg v. Commissioner were whether Form 4549 (Income Tax Examination Changes) is a binding contract and whether the interest under IRC § 6404(e)(1) should be abated. A number of other issues including collateral and equitable estoppel were raised, but the Tax Court found that they were

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Scott St. Amand April 2, 2020
Business Related Issues
Adjustments

Manroe v. Commissioner
T.C. Memo. 2020-16

On January 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Manroe v. Commissioner (T.C. Memo. 2020-16). The issue presented in Manroe v. Commissioner was whether the Tax Court had jurisdiction over the partners to redetermine the penalties at issue in a partner-level proceeding. Background to Manroe v. Commissioner The case stems from a tax shelter transaction, in which the petitioners ultimately conceded that the partnership at issue was a sham,

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Scott St. Amand January 22, 2020
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Successor Liability in a Purchase of Corporate Assets

As a tax controversy lawyer, most of your clients come to you in quite a predicament with the IRS, rather than coming to you to avoid said predicament. Such is the case when Cousin Elmer comes to visit you one dismal winter day. You may remember Elmer from our article

Read More »
Scott St. Amand April 29, 2021

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

Read More »
Scott St. Amand September 9, 2020

Goldberg v. Commissioner
T.C. Memo. 2020-38

On April 2, 2020, the Tax Court issued a 163-page Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2020-38). The issues properly before the court in Goldberg v. Commissioner were whether Form 4549 (Income Tax Examination Changes) is a binding contract and whether the interest under IRC

Read More »
Scott St. Amand April 2, 2020

Manroe v. Commissioner
T.C. Memo. 2020-16

On January 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Manroe v. Commissioner (T.C. Memo. 2020-16). The issue presented in Manroe v. Commissioner was whether the Tax Court had jurisdiction over the partners to redetermine the penalties at issue in a partner-level proceeding. Background to

Read More »
Scott St. Amand January 22, 2020