CDP

Long v. Commissioner (T.C. Memo. 2021-81)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Long v. Commissioner (T.C. Memo. 2021-81). The primary issue presented in Long was whether the petitioner was entitled to dispute her underlying liabilities when she failed to do so with prior opportunity arising out of a notice of deficiency that was mailed to the petitioner’s last known address—which she did not receive. Underlying Liability in CDP Case A taxpayer’s underlying

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CDP Appeal

Benson v. Commissioner (T.C. Memo. 2021-78)

On June 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Benson v. Commissioner (T.C. Memo. 2021-78). The primary issue presented in Benson was whether the petitioner was precluded from challenging his underlying liabilities in a CDP case. Background The petitioner has sought to challenge his 2008 and 2009 tax liabilities both in his CDP hearing and in this Court. The petitioner had two prior opportunities to contest his underlying liabilities

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Books and Records

Lufkin v. Commissioner (T.C. Memo. 2021-71)

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Lufkin v. Commissioner (T.C. Memo. 2021-71). The primary issue presented in Lufkin was whether the pro se petitioner was liable for certain Form 941 liabilities. Background The IRS assessed the Form 941 liabilities, which arose in connection with the petitioner’s law practice, for the periods at issue in December 1998 and June 1999, respectively. After the petitioner underwent multiple chapter

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Appeals

Mason v. Commissioner (T.C. Memo. 2021-64)

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Mason v. Commissioner (T.C. Memo. 2021-64). The primary issue presented in Mason was whether Appeals abused its discretion by reviewing the Centralized Unit’s decision for abuse of discretion instead of reviewing the Masons’ offer on its merits. Background: A Lesson in Bureaucracy Victor and Katherine Mason owed back taxes. They didn’t deny it, but they said they didn’t have the

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Taxing, Briefly
Abuse of Discretion

Taxing, Briefly: The IRS Collection Process

The Basic Principles of Collection In our previous post, we discussed how audits are performed and your available options throughout the examination process.  Once the audit is complete, and all administrative and legal remedies are exhausted, how does the IRS actually collect taxes?  The first step in the IRS collection process is assessment. The IRS cannot collect a tax until it has assessed it. There are a bevy of rules surrounding assessments.  In general, the

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Abuse of Discretion

American Limousines, Inc. v. Commissioner (T.C. Memo. 2021-36)

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of American Limousines, Inc. v. Commissioner (T.C. Memo. 2021-36). The primary issues presented in American Limousines were whether the IRS abused its discretion in rejecting an installment agreement (that the petitioner could not fund) and whether the IRS abused its discretion in refusing to classify the petitioner’s account as currently not collectible. Background The petitioner is liable for unpaid employment taxes

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Abuse of Discretion

Smith v. Commissioner (T.C. Memo. 2021-29)

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smith v. Commissioner (T.C. Memo. 2021-29). The primary issues presented in Smith were whether a photocopy of an original purported return, for which the IRS has no record and on which the petitioner expects the IRS to act in making a refund, purports to be a return of income tax, and whether the petitioner was liable for the IRC §

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Long v. Commissioner (T.C. Memo. 2021-81)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Long v. Commissioner (T.C. Memo. 2021-81). The primary issue presented in Long was whether the petitioner was entitled to dispute her underlying liabilities when she failed to do so with prior opportunity arising out of

Read More »

Benson v. Commissioner (T.C. Memo. 2021-78)

On June 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Benson v. Commissioner (T.C. Memo. 2021-78). The primary issue presented in Benson was whether the petitioner was precluded from challenging his underlying liabilities in a CDP case. Background The petitioner has sought to challenge his

Read More »

Lufkin v. Commissioner (T.C. Memo. 2021-71)

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Lufkin v. Commissioner (T.C. Memo. 2021-71). The primary issue presented in Lufkin was whether the pro se petitioner was liable for certain Form 941 liabilities. Background The IRS assessed the Form 941 liabilities, which arose

Read More »

Mason v. Commissioner (T.C. Memo. 2021-64)

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Mason v. Commissioner (T.C. Memo. 2021-64). The primary issue presented in Mason was whether Appeals abused its discretion by reviewing the Centralized Unit’s decision for abuse of discretion instead of reviewing the Masons’ offer on

Read More »

Taxing, Briefly: The IRS Collection Process

The Basic Principles of Collection In our previous post, we discussed how audits are performed and your available options throughout the examination process.  Once the audit is complete, and all administrative and legal remedies are exhausted, how does the IRS actually collect taxes?  The first step in the IRS collection

Read More »

American Limousines, Inc. v. Commissioner (T.C. Memo. 2021-36)

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of American Limousines, Inc. v. Commissioner (T.C. Memo. 2021-36). The primary issues presented in American Limousines were whether the IRS abused its discretion in rejecting an installment agreement (that the petitioner could not fund) and whether

Read More »

Smith v. Commissioner (T.C. Memo. 2021-29)

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smith v. Commissioner (T.C. Memo. 2021-29). The primary issues presented in Smith were whether a photocopy of an original purported return, for which the IRS has no record and on which the petitioner expects the

Read More »