Challenging Underlying Liability

Cashaw v. Commissioner (T.C. Memo. 2021-123)

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Cashaw v. Commissioner (T.C. Memo. 2021-123). The primary issue presented in Cashaw was whether the petitioner is liable for trust fund recovery penalties. Held: Yup. Background to Cashaw v. Commissioner The petitioner was presented with difficult choices during her tenure as temporary chief administrator of a hospital. The hospital was under a state order freezing its bank accounts except for

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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 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 TEFRA proceedings

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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 were whether the petitioner was liable for the unpaid tax related to unreported IRC § 1231 gain Holding: Indeed she was. Background During 2013, the petitioner in Dodd v. Commissioner was employed as the office manager of a law firm in Washington, D.C. During 2013, and continuing at

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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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Procedural Issues
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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Procedural Issues
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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Procedural Issues
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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Cashaw v. Commissioner (T.C. Memo. 2021-123)

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Cashaw v. Commissioner (T.C. Memo. 2021-123). The primary issue presented in Cashaw was whether the petitioner is liable for trust fund recovery penalties. Held: Yup. Background to Cashaw v. Commissioner The petitioner was presented with

Read More »

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 was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier Notice of

Read More »

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 were whether the petitioner was liable for the unpaid tax related to unreported IRC § 1231 gain Holding: Indeed she was. Background During

Read More »

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 »

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 »