Penalties Under the Code
Challenging Underlying Liability

Bishop v. Commissioner
T.C. Memo. 2020-36

On March 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Bishop v. Commissioner (T.C. Memo. 2020-36). The issues presented in Bishop v. Commissioner were whether the petitioner could raise underlying tax liabilities before the Tax Court, and whether the IRS abused its discretion in upholding a proposed levy. Background to Bishop v. Commissioner The petitioner filed delinquent Federal income tax returns for 2013 and 2014 reporting self-employment income. For each

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Scott St. Amand March 17, 2020
Procedural Issues
A Petitioner Named Do-Wong

Wong v. Commissioner
T.C. Memo. 2020-32

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Wong v. Commissioner (T.C. Memo. 2020-32). The single issue presented in Wong v. Commissioner was whether Wong was right, which is to say, whether the IRS’s determination to sustain the collection action against the petitioner was proper as a matter of law. Background to Wong v. Commissioner Petitioner, Do Wong, filed a timely Federal income tax return for 2013, reporting

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Scott St. Amand March 5, 2020
Procedural Issues
Abuse of Discretion

Northside Carting Inc. v. Commissioner
T.C. Memo. 2020-18

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Northside Carting Inc. v. Commissioner (T.C. Memo. 2020-18). The primary issue presented in Northside Carting Inc. v. Commissioner was whether the IRS abused its discretion by rejecting collection alternatives (an installment agreement) raised in an equivalent hearing. Background to Northside Carting Inc. v. Commissioner The petitioner’s business is garbage and has been garbage since 1996. At the time the petition was

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Scott St. Amand January 23, 2020
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Bishop v. Commissioner
T.C. Memo. 2020-36

On March 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Bishop v. Commissioner (T.C. Memo. 2020-36). The issues presented in Bishop v. Commissioner were whether the petitioner could raise underlying tax liabilities before the Tax Court, and whether the IRS abused its discretion in upholding

Read More »
Scott St. Amand March 17, 2020

Wong v. Commissioner
T.C. Memo. 2020-32

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Wong v. Commissioner (T.C. Memo. 2020-32). The single issue presented in Wong v. Commissioner was whether Wong was right, which is to say, whether the IRS’s determination to sustain the collection action against the petitioner

Read More »
Scott St. Amand March 5, 2020

Northside Carting Inc. v. Commissioner
T.C. Memo. 2020-18

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Northside Carting Inc. v. Commissioner (T.C. Memo. 2020-18). The primary issue presented in Northside Carting Inc. v. Commissioner was whether the IRS abused its discretion by rejecting collection alternatives (an installment agreement) raised in an equivalent

Read More »
Scott St. Amand January 23, 2020