Procedural Issues
Cash Bond

Ahmed v. Commissioner
T.C. Memo. 2021-142

On December 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Ahmed v. Commissioner (T.C. Memo. 2021-142). The primary issue presented in Ahmed was whether the taxpayer’s payment of all monies owed mooted his challenge to the IRS’s imposition of a lien and the trust fund recovery penalty (“TFRP”). Held: Yup. Background to Ahmed v. Commissioner In June 2020, the petitioner sent to the IRS a check for $625,000 along with

Read More »
Scott St. Amand April 28, 2022
Income Tax Issues
Deposit of Partial Payment of Liabilities

Partial Payments of Tax and Deposits with the IRS

Sunday afternoon rolls around, and the last thing on your mind was explaining the pros and cons of making partial payments of tax and deposits with the IRS to a relative who still sees “Charlie” lurking in his backyard from time to time. Nonetheless, of all of your relatives, Cousin Elmer is, surprisingly, the least offensive to you. You may remember that Elmer is currently working with only seven and a half fingers and a

Read More »
Scott St. Amand November 17, 2021
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Ahmed v. Commissioner
T.C. Memo. 2021-142

On December 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Ahmed v. Commissioner (T.C. Memo. 2021-142). The primary issue presented in Ahmed was whether the taxpayer’s payment of all monies owed mooted his challenge to the IRS’s imposition of a lien and the trust fund

Read More »
Scott St. Amand April 28, 2022

Partial Payments of Tax and Deposits with the IRS

Sunday afternoon rolls around, and the last thing on your mind was explaining the pros and cons of making partial payments of tax and deposits with the IRS to a relative who still sees “Charlie” lurking in his backyard from time to time. Nonetheless, of all of your relatives, Cousin

Read More »
Scott St. Amand November 17, 2021