Procedural Issues
Abuse of Discretion

Norberg v. Commissioner
T.C. Memo. 2022-30

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Norberg v. Commissioner (T.C. Memo. 2022-30). The primary issue presented in Norberg v. Commissioner was whether the settlement officer abused its discretion in upholding a notice of intent to levy and denying the petitioners’ request to be placed in currently not collectible status (despite having the ability to make payments). Held:  Background to Norberg v. Commissioner In February 2019, the

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Scott St. Amand January 24, 2023
Procedural Issues
Abuse of Discretion

Barnes v. Commissioner
T.C. Memo. 2021-49

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Barnes v. Commissioner (T.C. Memo. 2021-49). The primary issues presented in Barnes v. Commissioner were whether the statute of limitations on collections had run with respect to the petitioners 2003 liability, whether their 2003 tax liability had been discharged in bankruptcy, whether the IRS abused its discretion in sustaining a Notice of Federal Tax Lien as to the 2003 liability.

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Scott St. Amand May 4, 2021
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Norberg v. Commissioner
T.C. Memo. 2022-30

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Norberg v. Commissioner (T.C. Memo. 2022-30). The primary issue presented in Norberg v. Commissioner was whether the settlement officer abused its discretion in upholding a notice of intent to levy and denying the petitioners’ request

Read More »
Scott St. Amand January 24, 2023

Barnes v. Commissioner
T.C. Memo. 2021-49

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Barnes v. Commissioner (T.C. Memo. 2021-49). The primary issues presented in Barnes v. Commissioner were whether the statute of limitations on collections had run with respect to the petitioners 2003 liability, whether their 2003 tax

Read More »
Scott St. Amand May 4, 2021