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. 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 taxes

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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 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 and Failure

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Taxing, Briefly
Bankruptcy

Taxing, Briefly – Can the IRS Take My Passport?

When my son was two, his grandmother gave him a stuffed owl. Not a particularly creative toddler, he named the little owl Stuffy, and the name has stuck to this day.  What does this have to do with the question “Can the IRS Take My Passport?”  Patience…all will be revealed. He took the owl everywhere, which naturally led to many a calamity when Stuffy was inevitably misplaced. For my wife and I, Stuffy also had an

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Procedural Issues
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

The IRS Collection Process – Taxing, Briefly

The Basic Principles of the IRS Collection Process 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. 

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Procedural Issues
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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Procedural Issues
CDP

Galloway v. Commissioner (T.C. Memo. 2021-24)

On February 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Galloway v. Commissioner (T.C. Memo. 2021-24). The primary issue presented in Galloway was whether, during his CDP hearing, the petitioner was “improperly barred from resuscitating an offer-in-compromise” that had been rejected prior to the NFTL filing. Background By the time his second offer was rejected, the petitioner owed $81,500 in tax for 2014.  In 2016, he submitted an OIC for

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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. were whether the settlement officer: (1) properly verified that the requirements of applicable law or administrative procedure were met;

Read More »

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 was whether the settlement officer abused its discretion in rejecting the petitioners’ offer in compromise and by not performing a bankruptcy analysis. Initial

Read More »

Taxing, Briefly – Can the IRS Take My Passport?

When my son was two, his grandmother gave him a stuffed owl. Not a particularly creative toddler, he named the little owl Stuffy, and the name has stuck to this day.  What does this have to do with the question “Can the IRS Take My Passport?”  Patience…all will be revealed. He

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 »

The IRS Collection Process – Taxing, Briefly

The Basic Principles of the IRS Collection Process 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

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 »

Galloway v. Commissioner (T.C. Memo. 2021-24)

On February 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Galloway v. Commissioner (T.C. Memo. 2021-24). The primary issue presented in Galloway was whether, during his CDP hearing, the petitioner was “improperly barred from resuscitating an offer-in-compromise” that had been rejected prior to the NFTL

Read More »