Procedural Issues
Decision Letter

Ramey v. Commissioner
156 T.C. No. 1

On January 14, 2021, the Tax Court issued its opinion in Ramey v. Commissioner (156 T.C. No. 1). The underlying issue presented in Ramey v. Commissioner was whether notice sent to last known address, shared by multiple businesses, and not left with anyone authorized to receive the petitioner’s mail, started the CDP Appeal clock in IRC § 6330(a)(2) and (3). Legal Background to Ramey v. Commissioner The IRS may not make a levy unless the

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Scott St. Amand January 14, 2021
Procedural Issues
Decision Letter

Chang v. Commissioner
T.C. Memo. 2020-19

On January 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Chang v. Commissioner (T.C. Memo. 2020-19). The issues presented in Chang v. Commissioner were (1) whether petitioners timely mailed requests for CDP hearings; and if so (2) whether the Tax Court had jurisdiction to review the subsequent decision letters issued by the IRS. Equivalent Hearing in Chang v. Commissioner Where a person does not timely request a Collection Due Process

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Scott St. Amand January 29, 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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Ramey v. Commissioner
156 T.C. No. 1

On January 14, 2021, the Tax Court issued its opinion in Ramey v. Commissioner (156 T.C. No. 1). The underlying issue presented in Ramey v. Commissioner was whether notice sent to last known address, shared by multiple businesses, and not left with anyone authorized to receive the petitioner’s mail, started

Read More »
Scott St. Amand January 14, 2021

Chang v. Commissioner
T.C. Memo. 2020-19

On January 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Chang v. Commissioner (T.C. Memo. 2020-19). The issues presented in Chang v. Commissioner were (1) whether petitioners timely mailed requests for CDP hearings; and if so (2) whether the Tax Court had jurisdiction to review

Read More »
Scott St. Amand January 29, 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