Procedural Issues
Bankruptcy

Wathen v. Commissioner (T.C. Memo. 2021-100)

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Wathen v. Commissioner (T.C. Memo. 2021-100). The primary issues presented in Wathen were whether the petitioner failed to report income, whether the petitioner is entitled to deductions on Schedule C, whether the petitioner is liable for the failure to file penalty for 2010 and 2011, and whether the petitioner is liable for the substantial understatement accuracy-related penalty. Background to Wathen

Read More »
Procedural Issues
Estoppel

Bailey v. Commissioner (T.C. Memo. 2021-55)

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Bailey v. Commissioner (T.C. Memo. 2021-55). The primary issue presented in Bailey was whether the petitioners should (or could) be relieved from the stipulation of facts that they voluntarily entered into with the IRS before trial. Background The petitioners’ personal income tax returns (and a related corporate return) were audited for a number of years (from 2008-2012), and the IRS

Read More »
Burden of Proof

Jenkins v. Commissioner (T.C. Memo. 2021-54)

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Jenkins v. Commissioner (T.C. Memo. 2021-54). The primary issues presented in Jenkins was whether the IRS has proven fraud, and the amount of unreported income for the consolidated petitioners. Just a Head’s Up This opinion by Judge Holmes contains a “waddle” of penguins that speak in French, a forged Kerguelenois diplomatic passport, and a simile comparing the IRS to a

Read More »
Income Tax Issues
Bank Deposits Analysis

Martin v. Commissioner (T.C. Memo. 2021-35)

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for penalties for filing (very) late and for being (very) negligent and for (very) substantially understating their liabilities. Background to NOLs The petitioner-husband was a racecar driver and

Read More »
Closing Agreements as Contracts

Howe v. Commissioner (T.C. Memo. 2020-78)

On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Howe v. Commissioner (T.C. Memo. 2020-78). The issues before the court in Howe were (1) whether the notice of deficiency is valid and (2) whether respondent is equitably estopped from denying the executed settlement agreement in Form 870-AD (Offer to Waive Restrictions on Assessment and Collection of Tax Deficiency and to Accept Overassessment).

Read More »
Procedural Issues
CDP Appeal

Richlin v. Commissioner (T.C. Memo. 2020-60)

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Richlin v. Commissioner (T.C. Memo. 2020-60). The issues before the court in Richlin were (1) whether Form 12257 (Summary Notice of Determination, Waiver of Right to Judicial Review of a Collection Due Process Determination, and Waiver of Suspension of Levy Action) is a binding contract between the petitioner and the IRS; (2) whether IRM 8.22.9.13 prohibits rescission of a Form

Read More »
A Petitioner Named Dung

Tran v. Commissioner (T.C. Memo. 2020-27)

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for 2006; (2) whether the petitioners failed to report gross receipts on Schedule C (Profits or Loss From Business) with regard to their nail salons in 2004, 2005,

Read More »
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Wathen v. Commissioner (T.C. Memo. 2021-100)

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Wathen v. Commissioner (T.C. Memo. 2021-100). The primary issues presented in Wathen were whether the petitioner failed to report income, whether the petitioner is entitled to deductions on Schedule C, whether the petitioner is liable

Read More »

Bailey v. Commissioner (T.C. Memo. 2021-55)

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Bailey v. Commissioner (T.C. Memo. 2021-55). The primary issue presented in Bailey was whether the petitioners should (or could) be relieved from the stipulation of facts that they voluntarily entered into with the IRS before

Read More »

Jenkins v. Commissioner (T.C. Memo. 2021-54)

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Jenkins v. Commissioner (T.C. Memo. 2021-54). The primary issues presented in Jenkins was whether the IRS has proven fraud, and the amount of unreported income for the consolidated petitioners. Just a Head’s Up This opinion

Read More »

Martin v. Commissioner (T.C. Memo. 2021-35)

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for penalties for

Read More »

Howe v. Commissioner (T.C. Memo. 2020-78)

On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Howe v. Commissioner (T.C. Memo. 2020-78). The issues before the court in Howe were (1) whether the notice of deficiency is valid and (2) whether respondent is equitably estopped from denying the executed settlement agreement

Read More »

Richlin v. Commissioner (T.C. Memo. 2020-60)

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Richlin v. Commissioner (T.C. Memo. 2020-60). The issues before the court in Richlin were (1) whether Form 12257 (Summary Notice of Determination, Waiver of Right to Judicial Review of a Collection Due Process Determination, and

Read More »

Tran v. Commissioner (T.C. Memo. 2020-27)

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for 2006; (2)

Read More »