Business Related Issues
CDP

Goldberg v. Commissioner
T.C. Memo. 2021-119

On October 19, 2021, the Tax Court issued a Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2021-119). The primary issue presented in Goldberg v. Commissioner was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC § 6320 or because of his nonparticipation in an even earlier

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Scott St. Amand November 3, 2021
Income Tax Issues
Abuse of Discretion

Dodd v. Commissioner
T.C. Memo. 2021-118

On October 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Dodd v. Commissioner (T.C. Memo. 2021-118). The primary issue presented in Dodd v. Commissioner were whether the petitioner was liable for the unpaid tax related to unreported IRC § 1231 gain Holding: Indeed she was. Background to Dodd v. Commissioner During 2013, the petitioner in Dodd v. Commissioner was employed as the office manager of a law firm in Washington,

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Scott St. Amand October 25, 2021
Income Tax Issues
CDP

Parker v. Commissioner
T.C. Memo. 2021-111

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Parker v. Commissioner (T.C. Memo. 2021-111). The primary issues presented in Parker v. Commissioner were (1) whether petitioners can deduct, on Schedule C (Profit or Loss From Business), car and truck expenses in excess of the amount the IRS allowed; (2) whether petitioners can deduct retirement contributions in excess of the amount the IRS allowed; (3) whether petitioners can deduct expenses

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Scott St. Amand October 10, 2021
Procedural Issues
Abuse of Discretion

Kidz University Inc. v. Commissioner
T.C. Memo. 2021-101

On August 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Kidz University Inc. v. Commissioner (T.C. Memo. 2021-101). The primary issues presented in Kidz University Inc. v. Commissioner were whether the settlement officer: (1) properly verified that the requirements of applicable law or administrative procedure were met; (2) considered any relevant issues Kidz University raised; and (3) considered whether any proposed collection action balances the need for the efficient collection of

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Scott St. Amand October 1, 2021
Procedural Issues
CDP

Mohsen v. Commissioner
T.C. Memo. 2021-99

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Mohsen v. Commissioner (T.C. Memo. 2021-99). The primary issues presented in Mohsen v. Commissioner were whether the Tax Court possessed jurisdiction to decide the taxpayer’s claim for refund and whether the taxpayer’s unpaid income tax liability could be offset by a claimed (time-barred) credit. Filing Background to Mohsen v. Commissioner On April 15, 2002, the petitioner mailed the IRS a

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Scott St. Amand September 29, 2021
Procedural Issues
Abuse of Discretion

Abraham v. Commissioner
T.C. Memo. 2021-97

On August 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Abraham v. Commissioner (T.C. Memo. 2021-97). The primary issue presented in Abraham v. Commissioner  was whether the settlement officer abused its discretion in rejecting the petitioners’ offer in compromise and by not performing a bankruptcy analysis. Initial Observations about Abraham v. Commissioner Father Abraham three wives—Hagar, Sarah, and Keteurah. Jerry Abraham had one wife. Her name was Debra. The Returns

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Scott St. Amand September 27, 2021
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Goldberg v. Commissioner
T.C. Memo. 2021-119

On October 19, 2021, the Tax Court issued a Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2021-119). The primary issue presented in Goldberg v. Commissioner was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier

Read More »
Scott St. Amand November 3, 2021

Dodd v. Commissioner
T.C. Memo. 2021-118

On October 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Dodd v. Commissioner (T.C. Memo. 2021-118). The primary issue presented in Dodd v. Commissioner were whether the petitioner was liable for the unpaid tax related to unreported IRC § 1231 gain Holding: Indeed she was.

Read More »
Scott St. Amand October 25, 2021

Parker v. Commissioner
T.C. Memo. 2021-111

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Parker v. Commissioner (T.C. Memo. 2021-111). The primary issues presented in Parker v. Commissioner were (1) whether petitioners can deduct, on Schedule C (Profit or Loss From Business), car and truck expenses in excess of the

Read More »
Scott St. Amand October 10, 2021

Kidz University Inc. v. Commissioner
T.C. Memo. 2021-101

On August 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Kidz University Inc. v. Commissioner (T.C. Memo. 2021-101). The primary issues presented in Kidz University Inc. v. Commissioner were whether the settlement officer: (1) properly verified that the requirements of applicable law or administrative procedure were

Read More »
Scott St. Amand October 1, 2021

Mohsen v. Commissioner
T.C. Memo. 2021-99

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Mohsen v. Commissioner (T.C. Memo. 2021-99). The primary issues presented in Mohsen v. Commissioner were whether the Tax Court possessed jurisdiction to decide the taxpayer’s claim for refund and whether the taxpayer’s unpaid income tax

Read More »
Scott St. Amand September 29, 2021

Abraham v. Commissioner
T.C. Memo. 2021-97

On August 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Abraham v. Commissioner (T.C. Memo. 2021-97). The primary issue presented in Abraham v. Commissioner  was whether the settlement officer abused its discretion in rejecting the petitioners’ offer in compromise and by not performing a bankruptcy

Read More »
Scott St. Amand September 27, 2021