Procedural Issues
CDP Hearing

DelPonte v. Commissioner
158 T.C. No. 7

On May 5, 2022, the Tax Court issued the full opinion in DelPonte v. Commissioner (158 T.C. No. 7). The primary issue presented in DelPonte v. Commissioner was whether the IRS’s Cincinnati Centralized Innocent Spouse Operation (CCISO) or the IRS’s Office of Chief Counsel has the final authority to determine whether taxpayer was entitled to innocent spouse relief when such relief is first raised as an affirmative defense in a Tax Court petition. Held: Chief

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Scott St. Amand June 15, 2022
Income Tax Issues
Collection Due Process

Estate of Washington v. Commissioner
T.C. Memo. 2022-4

On February 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Estate of Washington v. Commissioner (T.C. Memo. 2022-4). The primary issue presented in Estate of Washington was whether offers-in-compromise presented by the estate qualified for effective tax administration consideration. No George and Martha Mr. Washington (Tony) wed Mrs. Washington (Lenda) in 1981. They had one child. They divorced in 2006. Mr. Washington had unpaid income tax liabilities for 2008, 2009,

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Scott St. Amand May 9, 2022
Procedural Issues
CDP Hearing

Ruhaak v. Commissioner
157 T.C. No. 9

On November 16, 2021, the Tax Court issued its opinion in Ruhaak v. Commissioner, 157 T.C. No. 9. The primary issue presented in Ruhaak was whether the petitioner’s request for a hearing made before the expiration of the 30-day period following the mailing date of the levy notice necessarily triggered a CDP hearing and not an equivalent hearing. Held: Timing is everything. Background to Ruhaak v. Commissioner The IRS sent the petitioner a Notice of

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Scott St. Amand April 15, 2022
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DelPonte v. Commissioner
158 T.C. No. 7

On May 5, 2022, the Tax Court issued the full opinion in DelPonte v. Commissioner (158 T.C. No. 7). The primary issue presented in DelPonte v. Commissioner was whether the IRS’s Cincinnati Centralized Innocent Spouse Operation (CCISO) or the IRS’s Office of Chief Counsel has the final authority to determine

Read More »
Scott St. Amand June 15, 2022

Estate of Washington v. Commissioner
T.C. Memo. 2022-4

On February 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Estate of Washington v. Commissioner (T.C. Memo. 2022-4). The primary issue presented in Estate of Washington was whether offers-in-compromise presented by the estate qualified for effective tax administration consideration. No George and Martha Mr. Washington

Read More »
Scott St. Amand May 9, 2022

Ruhaak v. Commissioner
157 T.C. No. 9

On November 16, 2021, the Tax Court issued its opinion in Ruhaak v. Commissioner, 157 T.C. No. 9. The primary issue presented in Ruhaak was whether the petitioner’s request for a hearing made before the expiration of the 30-day period following the mailing date of the levy notice necessarily triggered

Read More »
Scott St. Amand April 15, 2022