Taxing, Briefly
Assessment

Statutes of Limitation on Assessment and Collection

One of the most common questions I am asked by taxpayers is “How long can the IRS try to collect my liability?” It’s a good question, and one that would seem to have a quick, easy answer. Judging purely by the length of this article, however, the answer is never as simple as it might seem. On Statutes of Limitation on Assessment and Collection With the full understanding that “It depends” is the least satisfying

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Scott St. Amand November 12, 2021
Procedural Issues
Aunt Ethel

Extinguishment of Liens on Defeasible Property

A part of you couldn’t be happier that Uncle Bill obtained the services of another lawyer for one of his stick-it-to-the-man schemes. In this case, Bill wanted to avoid probate and transfer his home in Dixie County, Florida to his son Jethro. Bill and Ethel, however, still wanted to live in the house and wanted to be able to sell the house if Jethro pissed them off, which, in your experience, was a foregone conclusion.

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Scott St. Amand April 29, 2021
Procedural Issues
Burden of Proof

Lander v. Commissioner
154 T.C. No. 7

On March 12, 2020, the Tax Court issued its opinion in Lander v. Commissioner (154 T.C. No. 7). The issue presented in Lander v. Commissioner was whether the petitioners, who did not receive the statutory notice of deficiency (SNOD) mailed to their last known address, could challenge their underlying tax liability in a collection due process (CDP) proceeding. Public Service Announcement from Lander v. Commissioner You may have come to this post because you are

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Scott St. Amand March 12, 2020
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Statutes of Limitation on Assessment and Collection

One of the most common questions I am asked by taxpayers is “How long can the IRS try to collect my liability?” It’s a good question, and one that would seem to have a quick, easy answer. Judging purely by the length of this article, however, the answer is never

Read More »
Scott St. Amand November 12, 2021

Extinguishment of Liens on Defeasible Property

A part of you couldn’t be happier that Uncle Bill obtained the services of another lawyer for one of his stick-it-to-the-man schemes. In this case, Bill wanted to avoid probate and transfer his home in Dixie County, Florida to his son Jethro. Bill and Ethel, however, still wanted to live

Read More »
Scott St. Amand April 29, 2021

Lander v. Commissioner
154 T.C. No. 7

On March 12, 2020, the Tax Court issued its opinion in Lander v. Commissioner (154 T.C. No. 7). The issue presented in Lander v. Commissioner was whether the petitioners, who did not receive the statutory notice of deficiency (SNOD) mailed to their last known address, could challenge their underlying tax

Read More »
Scott St. Amand March 12, 2020