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
Business Related Issues
Alimony

Schroeder v. Commissioner
T.C. Memo. 2020-117

On August 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Schroeder v. Commissioner (T.C. Memo. 2020-117). The primary issue before the court in Schroeder was whether payments that petitioner-husband made to his petitioner-ex-wife and his divorce lawyer had the effect of increasing the basis in an LLC indirectly owned by petitioner-husband. Background to Schroeder v. Commissioner Petitioner-husband (PH) founded the partnership DCA, LLC in 2003. In 2008, PH assigned his

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Scott St. Amand August 5, 2020
Procedural Issues
Administrative Proceeding

Dennis v. Commissioner
T.C. Memo. 2020-98

On July 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Dennis v. Commissioner (T.C. Memo. 2020-98). The primary issue before the court in Dennis v. Commissioner was whether the petitioners were entitled to reasonable litigation or administrative costs when, after CDP appeals, petition, and remand from Tax Court to Appeals, the IRS conceded all issues. Brief Background in Dennis v. Commissioner The IRS screwed this one up, but they were

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Scott St. Amand July 1, 2020
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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

Schroeder v. Commissioner
T.C. Memo. 2020-117

On August 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Schroeder v. Commissioner (T.C. Memo. 2020-117). The primary issue before the court in Schroeder was whether payments that petitioner-husband made to his petitioner-ex-wife and his divorce lawyer had the effect of increasing the basis in

Read More »
Scott St. Amand August 5, 2020

Dennis v. Commissioner
T.C. Memo. 2020-98

On July 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Dennis v. Commissioner (T.C. Memo. 2020-98). The primary issue before the court in Dennis v. Commissioner was whether the petitioners were entitled to reasonable litigation or administrative costs when, after CDP appeals, petition, and remand

Read More »
Scott St. Amand July 1, 2020