Penalties Under the Code
CDP

Friendship Creative Printers Inc. v. Commissioner
T.C. Memo. 2021-19

On February 22, 2021, the Tax Court issued a Memorandum Opinion in the case of Friendship Creative Printers Inc. v. Commissioner (T.C. Memo. 2021-19). The primary issue presented in Friendship Creative was whether the IRS abused its discretion in sustaining a proposed levy action in collection of over $200,000, arising out of the petitioner’s employment tax liabilities and associated penalties. Background to Friendship Creative Printers Inc. v. Commissioner In 2013, the petitioner did not timely

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Scott St. Amand February 22, 2021
Procedural Issues
Collection Alternatives

Spagnoletti v. Commissioner
T.C. Memo. 2020-140

On October 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Spagnoletti v. Commissioner (T.C. Memo. 2020-140). The issue before the court in Spagnoletti v. Commissioner was whether the IRS abused its discretion in sustaining the proposed levy when it denied the petitioner’s request, who requested to full pay his liability in four payments but failed to submit financial documentation. Background to Spagnoletti v. Commissioner The petitioner (an attorney) filed delinquent

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Scott St. Amand October 8, 2020
Failure to Communicate with IRS

Lloyd v. Commissioner
T.C. Memo. 2020-92

On June 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Lloyd v. Commissioner (T.C. Memo. 2020-92). The issue before the court in Lloyd v. Commissioner was whether a taxpayer’s claims that “the income tax law is null and void” and that “he is entitled to a religious exemption from paying income tax because he is functioning as a church relieves him from the requirement to file and/or pay Federal income

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Scott St. Amand June 22, 2020
Procedural Issues
Collection Alternatives

Nimmo v. Commissioner
T.C. Memo. 2020-72

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Nimmo v. Commissioner (T.C. Memo. 2020-72). The sole issue before the court in Nimmo v. Commissioner was whether the IRS abused its discretion in sustaining the collection action against petitioner, who failed to attend (call into) his initial CDP hearing, failed to submit required documentation at his subsequent CDP hearing (on another tax period), and otherwise failed to communicate with

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Scott St. Amand June 1, 2020
Procedural Issues
A Petitioner Named Do-Wong

Wong v. Commissioner
T.C. Memo. 2020-32

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Wong v. Commissioner (T.C. Memo. 2020-32). The single issue presented in Wong v. Commissioner was whether Wong was right, which is to say, whether the IRS’s determination to sustain the collection action against the petitioner was proper as a matter of law. Background to Wong v. Commissioner Petitioner, Do Wong, filed a timely Federal income tax return for 2013, reporting

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Scott St. Amand March 5, 2020
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Friendship Creative Printers Inc. v. Commissioner
T.C. Memo. 2021-19

On February 22, 2021, the Tax Court issued a Memorandum Opinion in the case of Friendship Creative Printers Inc. v. Commissioner (T.C. Memo. 2021-19). The primary issue presented in Friendship Creative was whether the IRS abused its discretion in sustaining a proposed levy action in collection of over $200,000, arising

Read More »
Scott St. Amand February 22, 2021

Spagnoletti v. Commissioner
T.C. Memo. 2020-140

On October 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Spagnoletti v. Commissioner (T.C. Memo. 2020-140). The issue before the court in Spagnoletti v. Commissioner was whether the IRS abused its discretion in sustaining the proposed levy when it denied the petitioner’s request, who requested

Read More »
Scott St. Amand October 8, 2020

Lloyd v. Commissioner
T.C. Memo. 2020-92

On June 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Lloyd v. Commissioner (T.C. Memo. 2020-92). The issue before the court in Lloyd v. Commissioner was whether a taxpayer’s claims that “the income tax law is null and void” and that “he is entitled to

Read More »
Scott St. Amand June 22, 2020

Nimmo v. Commissioner
T.C. Memo. 2020-72

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Nimmo v. Commissioner (T.C. Memo. 2020-72). The sole issue before the court in Nimmo v. Commissioner was whether the IRS abused its discretion in sustaining the collection action against petitioner, who failed to attend (call

Read More »
Scott St. Amand June 1, 2020

Wong v. Commissioner
T.C. Memo. 2020-32

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Wong v. Commissioner (T.C. Memo. 2020-32). The single issue presented in Wong v. Commissioner was whether Wong was right, which is to say, whether the IRS’s determination to sustain the collection action against the petitioner

Read More »
Scott St. Amand March 5, 2020