Income Tax Issues
Collection Due Process

Estate of Washington v. Commissioner
T.C. Memo. 2022-4

On February 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Estate of Washington v. Commissioner (T.C. Memo. 2022-4). The primary issue presented in Estate of Washington was whether offers-in-compromise presented by the estate qualified for effective tax administration consideration. No George and Martha Mr. Washington (Tony) wed Mrs. Washington (Lenda) in 1981. They had one child. They divorced in 2006. Mr. Washington had unpaid income tax liabilities for 2008, 2009,

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Scott St. Amand May 9, 2022
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
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 v. Commissioner 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

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Scott St. Amand October 4, 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
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Estate of Washington v. Commissioner
T.C. Memo. 2022-4

On February 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Estate of Washington v. Commissioner (T.C. Memo. 2022-4). The primary issue presented in Estate of Washington was whether offers-in-compromise presented by the estate qualified for effective tax administration consideration. No George and Martha Mr. Washington

Read More »
Scott St. Amand May 9, 2022

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

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 v. Commissioner was whether Appeals abused its discretion when it declined to place the petitioner in currently not collectible (CNC) status. Background to Webb

Read More »
Scott St. Amand October 4, 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