Bell Capital Management, Inc. v. Commissioner (T.C. Memo. 2021-74) On June 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Bell Capital Management, Inc.v. Commissioner (T.C. Memo. 2021-74). The primary issues presented in Bell Capital Management, Inc. were whether (1) petitioner is collaterally estopped from denying that it was responsible for paying the employment taxes; (2) whether the IRS properly determined that Ron H. Bell should be legally classified as petitioner’s