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
Collection Due Process

Webb v. Commissioner (T.C. Memo. 2021-105)

On August 31, 2021, the Tax Court issued a Memorandum Opinion in the case of Webb v. Commissioner (T.C. Memo. 2021-105). The primary issue presented in Webb was whether Appeals abused its discretion when it declined to place the petitioner in currently not collectible (CNC) status. Background to Webb v. Commissioner On March 4, 2019, the IRS issued to the petitioner a Notice of Intent to Levy and Notice of Your Right to a Hearing

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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
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 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 Form 4868

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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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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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Procedural Issues
Collection Due Process Hearing

Estate of Lee v. Commissioner (T.C. Memo. 2021-92)

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Lee v. Commissioner (T.C. Memo. 2021-92). The primary issue presented in Estate of Lee was whether the IRS abused its discretion in rejecting the petitioner’s offer-in-compromise by erring to properly compute the estate’s reasonable collection potential by including amounts distributed by the executor. Challenging the IRS Lien before Appeals IRC § 6320(b) permits a taxpayer to challenge an

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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 »

Webb v. Commissioner (T.C. Memo. 2021-105)

On August 31, 2021, the Tax Court issued a Memorandum Opinion in the case of Webb v. Commissioner (T.C. Memo. 2021-105). The primary issue presented in Webb was whether Appeals abused its discretion when it declined to place the petitioner in currently not collectible (CNC) status. Background to Webb v.

Read More »

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 »

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 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

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 »

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 »

Estate of Lee v. Commissioner (T.C. Memo. 2021-92)

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Lee v. Commissioner (T.C. Memo. 2021-92). The primary issue presented in Estate of Lee was whether the IRS abused its discretion in rejecting the petitioner’s offer-in-compromise by erring to properly compute the estate’s

Read More »