Procedural Issues
Burden of Proof

Lander v. Commissioner
154 T.C. No. 7

On March 12, 2020, the Tax Court issued its opinion in Lander v. Commissioner (154 T.C. No. 7). The issue presented in Lander v. Commissioner was whether the petitioners, who did not receive the statutory notice of deficiency (SNOD) mailed to their last known address, could challenge their underlying tax liability in a collection due process (CDP) proceeding. Public Service Announcement from Lander v. Commissioner You may have come to this post because you are

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Scott St. Amand March 12, 2020
Income Tax Issues
Admissibility of Evidence

Grieve v. Commissioner
T.C. Memo. 2020-28

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve v. Commissioner was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to the petitioner from a GRAT and an irrevocable trust, respectively. Background to Grieve v. Commissioner – A Three Hour Tour This is the cautionary tale

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Scott St. Amand March 2, 2020
Penalties Under the Code
A Petitioner Named Dung

Tran v. Commissioner
T.C. Memo. 2020-27

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran v. Commissioner were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for 2006; (2) whether the petitioners failed to report gross receipts on Schedule C (Profits or Loss From Business) with regard to their nail salons in

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Scott St. Amand February 26, 2020
Income Tax Issues
Books and Records

Keels v. Commissioner
T.C. Memo. 2020-25

On February 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Keels v. Commissioner (T.C. Memo. 2020-25). The issues presented in Keels v. Commissioner were (1) whether petitioner substantiated his expenses underlying his claimed deductions by maintaining adequate records, and (2) whether, because the IRS raised the application of IRC § 409A as a new basis for disallowance of the petitioner’s deductions (which had not been raised in the notice of

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Scott St. Amand February 19, 2020
Penalties Under the Code
Burden of Proof

Isaacson v. Commissioner
T.C. Memo. 2020-17

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Isaacson v. Commissioner (T.C. Memo. 2020-17). The issues presented in Isaacson v. Commissioner were whether the petitioner (1) failed to report taxable income for tax year 2007, and (2) if so, was the petitioner, therefore, liable for the civil fraud penalty under IRC § 6663. Background to Isaacson v. Commissioner The petitioner, a trial attorney, who specialized in (among other

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Scott St. Amand January 23, 2020
Penalties Under the Code
Badges of Fraud

Purvis v. Commissioner
T.C. Memo. 2020-13

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Purvis v. Commissioner (T.C. Memo. 2020-13). The issue presented in Purvis v. Commissioner was whether the IRS overcame their burden of proof to establish the petitioners’ liability for the taxes and the fraud penalty under IRC § 6663(a).  What a crazy case… The Quick and Dirty Background of One of the Craziest Cases I’ve Ever Read (Purvis v. Commissioner) This

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Scott St. Amand January 14, 2020
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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Lander v. Commissioner
154 T.C. No. 7

On March 12, 2020, the Tax Court issued its opinion in Lander v. Commissioner (154 T.C. No. 7). The issue presented in Lander v. Commissioner was whether the petitioners, who did not receive the statutory notice of deficiency (SNOD) mailed to their last known address, could challenge their underlying tax

Read More »
Scott St. Amand March 12, 2020

Grieve v. Commissioner
T.C. Memo. 2020-28

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve v. Commissioner was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to

Read More »
Scott St. Amand March 2, 2020

Tran v. Commissioner
T.C. Memo. 2020-27

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran v. Commissioner were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for

Read More »
Scott St. Amand February 26, 2020

Keels v. Commissioner
T.C. Memo. 2020-25

On February 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Keels v. Commissioner (T.C. Memo. 2020-25). The issues presented in Keels v. Commissioner were (1) whether petitioner substantiated his expenses underlying his claimed deductions by maintaining adequate records, and (2) whether, because the IRS raised

Read More »
Scott St. Amand February 19, 2020

Isaacson v. Commissioner
T.C. Memo. 2020-17

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Isaacson v. Commissioner (T.C. Memo. 2020-17). The issues presented in Isaacson v. Commissioner were whether the petitioner (1) failed to report taxable income for tax year 2007, and (2) if so, was the petitioner, therefore,

Read More »
Scott St. Amand January 23, 2020

Purvis v. Commissioner
T.C. Memo. 2020-13

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Purvis v. Commissioner (T.C. Memo. 2020-13). The issue presented in Purvis v. Commissioner was whether the IRS overcame their burden of proof to establish the petitioners’ liability for the taxes and the fraud penalty under

Read More »
Scott St. Amand January 14, 2020

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