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
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
Audit Reconsideration

Pazden v. Commissioner
T.C. Memo. 2021-108

On September 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Pazden v. Commissioner (T.C. Memo. 2021-108). The primary issues presented in Pazden were (1) whether Ms. Pazden is entitled to challenge her underlying tax liability for 2010, and (2) whether Appeals abused its discretion in sustaining the proposed levy in this case. Held: Nope and Nope. Background Ms. Pazden failed to timely file her 2010 Federal income tax return. The

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Scott St. Amand October 7, 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
CDP

Disqualification of an IRS Appeals Officer for Prior Involvement

Background to a Fair Collection Due Process Hearing In a previous Taxing, Briefly article, we discussed the IRS collection process including Collection Due Process (CDP) appeal procedures.  As we noted in that article, a CDP appeal is a taxpayer’s opportunity to dispute the appropriateness of a lien or levy.[1] In this post, we’ll discuss the disqualification of an IRS Appeals Officer for prior involvement in a collection due process hearing and the IRS’s vehement arguments

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Scott St. Amand September 17, 2021
Procedural Issues
CDP

Belair v. Commissioner
157 T.C. No. 2

On August 2, 2021, the Tax Court issued its opinion in Belair v. Commissioner (157 T.C. No. 2). The primary issue presented in Belair v. Commissioner  was whether in a CDP nonliability case the traditional rules of summary judgment are appropriate. Holding in Belair v. Commissioner In a CDP nonliability case such as this, the Tax Court’s decision turns on whether the administrative record shows an abuse of discretion, and the Tax Court’s traditional rules of

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Scott St. Amand August 31, 2021
Procedural Issues
Appeals

Perfection of Imperfect CDP Appeals

On Latin Nerdery and Perfection of Imperfect CDP Appeals If you have read many of the posts on Briefly Taxing, it should come as no surprise to you that I was a Latin nerd in high school…and college…and at present. The truth of the matter is that I competed nationally, my specialty being Greek mythology. My sophomore year of high school I missed a single question on the national exam. One question. My Latin teacher,

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Scott St. Amand August 12, 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

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

Pazden v. Commissioner
T.C. Memo. 2021-108

On September 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Pazden v. Commissioner (T.C. Memo. 2021-108). The primary issues presented in Pazden were (1) whether Ms. Pazden is entitled to challenge her underlying tax liability for 2010, and (2) whether Appeals abused its discretion in

Read More »
Scott St. Amand October 7, 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

Disqualification of an IRS Appeals Officer for Prior Involvement

Background to a Fair Collection Due Process Hearing In a previous Taxing, Briefly article, we discussed the IRS collection process including Collection Due Process (CDP) appeal procedures.  As we noted in that article, a CDP appeal is a taxpayer’s opportunity to dispute the appropriateness of a lien or levy.[1] In

Read More »
Scott St. Amand September 17, 2021

Belair v. Commissioner
157 T.C. No. 2

On August 2, 2021, the Tax Court issued its opinion in Belair v. Commissioner (157 T.C. No. 2). The primary issue presented in Belair v. Commissioner  was whether in a CDP nonliability case the traditional rules of summary judgment are appropriate. Holding in Belair v. Commissioner In a CDP nonliability case

Read More »
Scott St. Amand August 31, 2021

Perfection of Imperfect CDP Appeals

On Latin Nerdery and Perfection of Imperfect CDP Appeals If you have read many of the posts on Briefly Taxing, it should come as no surprise to you that I was a Latin nerd in high school…and college…and at present. The truth of the matter is that I competed nationally,

Read More »
Scott St. Amand August 12, 2021