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
Income Tax Issues
Collection Alternatives

Swanberg v. Commissioner
T.C. Memo. 2020-123

On August 25, 2020, the Tax Court issued a Memorandum Opinion in the case of Swanberg v. Commissioner (T.C. Memo. 2020-123). The primary issue before the court in Swanberg v. Commissioner was whether the IRS abused its discretion in failing to consider the petitioner’s prior year credits in determining liability for the year under examination. Availability of Credit in Swanberg v. Commissioner If your client’s primary argument to avoid liability in year at issue is

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Scott St. Amand August 25, 2020
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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

Swanberg v. Commissioner
T.C. Memo. 2020-123

On August 25, 2020, the Tax Court issued a Memorandum Opinion in the case of Swanberg v. Commissioner (T.C. Memo. 2020-123). The primary issue before the court in Swanberg v. Commissioner was whether the IRS abused its discretion in failing to consider the petitioner’s prior year credits in determining liability

Read More »
Scott St. Amand August 25, 2020