Procedural Issues
Example of a Taxpayer Dragging His Ass

Rivas v. Commissioner
T.C. Memo. 2020-124

On August 25, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivas v. Commissioner (T.C. Memo. 2020-124). The primary issue before the court in Rivas v. Commissioner was whether the petitioner timely filed her petition.  Spoiler alert: she didn’t. Background to Rivas v. Commissioner The IRS mailed a notice of deficiency by certified mail petitioner on May 21, 2019. The notice of deficiency was sent both to the petitioner’s last known

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Scott St. Amand August 25, 2020
Procedural Issues
Example of a Taxpayer Dragging His Ass

Thomas v. Commissioner
T.C. Memo. 2020-33

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Thomas v. Commissioner (T.C. Memo. 2020-33). The single issue presented in Thomas v. Commissioner was whether the petitioners timely filed their petition within the time prescribed by IRC § 6213(a) or IRC § 7502, which in turn depended on whether a private postmark bearing a previous date to the USPS postmark was controlling. Background to Thomas v. Commissioner In November

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Scott St. Amand March 5, 2020
Procedural Issues
Deadlines for Filing

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which the petition was mailed bore no postmark. If so, then the Tax Court had jurisdiction to redetermine the deficiency.  If not, then no jurisdiction would

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Scott St. Amand January 13, 2020
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Rivas v. Commissioner
T.C. Memo. 2020-124

On August 25, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivas v. Commissioner (T.C. Memo. 2020-124). The primary issue before the court in Rivas v. Commissioner was whether the petitioner timely filed her petition.  Spoiler alert: she didn’t. Background to Rivas v. Commissioner The IRS

Read More »
Scott St. Amand August 25, 2020

Thomas v. Commissioner
T.C. Memo. 2020-33

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Thomas v. Commissioner (T.C. Memo. 2020-33). The single issue presented in Thomas v. Commissioner was whether the petitioners timely filed their petition within the time prescribed by IRC § 6213(a) or IRC § 7502, which

Read More »
Scott St. Amand March 5, 2020

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which

Read More »
Scott St. Amand January 13, 2020