Penalties Under the Code
Amended Returns

Harrington v. Commissioner
T.C. Memo. 2021-95

  On July 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Harrington v. Commissioner (T.C. Memo. 2021-95). The primary issue presented in Harrington was whether the IRS’s assessment was assessment is barred by the three-year period of limitations in IRC § 6501(a), or whether the statute of limitations remained open due to fraud under IRC § 6501(c)(1). Summary1 “Sarah, I feel like I don’t even know you.” “It’s Vivian. Would

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Scott St. Amand September 25, 2021
Procedural Issues
Amended Return is Admission by Taxpayer

The Truth about Amending Tax Returns

Clients are untrustworthy.  As a tax controversy attorney, this is my experience. I have heard that other types of law deals with more honorable sorts, but I’ll believe it when I see it.  When a client comes to you and says “whoopsie, I forgot to report [insert absurdly large number here] on my return, what should I do?” what should you tell him?  What if the IRS has already discovered the understatement?  Is he under

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Scott St. Amand July 13, 2021
Penalties Under the Code
Amended Return is Admission by Taxpayer

Mei Productions v. Commissioner
T.C. Memo. 2020-11

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Mei Productions v. Commissioner (T.C. Memo. 2020-11). The issue presented in Mei Productions v. Commissioner was whether the petitioner was liable for the failure to pay under IRC § 6651(a)(3) (failure to timely pay tax assessed as an amendment to an original return). Background to Mei Productions v. Commissioner The petitioner is a California corporation, which admitted that it erroneously claimed

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Scott St. Amand January 14, 2020
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Harrington v. Commissioner
T.C. Memo. 2021-95

  On July 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Harrington v. Commissioner (T.C. Memo. 2021-95). The primary issue presented in Harrington was whether the IRS’s assessment was assessment is barred by the three-year period of limitations in IRC § 6501(a), or whether the

Read More »
Scott St. Amand September 25, 2021

The Truth about Amending Tax Returns

Clients are untrustworthy.  As a tax controversy attorney, this is my experience. I have heard that other types of law deals with more honorable sorts, but I’ll believe it when I see it.  When a client comes to you and says “whoopsie, I forgot to report [insert absurdly large number

Read More »
Scott St. Amand July 13, 2021

Mei Productions v. Commissioner
T.C. Memo. 2020-11

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Mei Productions v. Commissioner (T.C. Memo. 2020-11). The issue presented in Mei Productions v. Commissioner was whether the petitioner was liable for the failure to pay under IRC § 6651(a)(3) (failure to timely pay tax assessed

Read More »
Scott St. Amand January 14, 2020