Procedural Issues
Administrative Costs

Morreale v. Commissioner
T.C. Memo. 2021-90

On July 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Morreale v. Commissioner (T.C. Memo. 2021-90). The primary issue presented in Morreale v. Commissioner was whether the petitioner was entitled for reasonable litigation fees from the IRS. Background to Morreale v. Commissioner The petitioner filed a Tax Court petition in November 2017 disputing certain adjustments to his return. The petitioner and the IRS settled in January 2019, with the IRS

Read More »
Scott St. Amand August 3, 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.

Read More »
Scott St. Amand November 9, 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

Read More »
Scott St. Amand July 1, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Morreale v. Commissioner
T.C. Memo. 2021-90

On July 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Morreale v. Commissioner (T.C. Memo. 2021-90). The primary issue presented in Morreale v. Commissioner was whether the petitioner was entitled for reasonable litigation fees from the IRS. Background to Morreale v. Commissioner The petitioner filed

Read More »
Scott St. Amand August 3, 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

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