Penalties Under the Code
Bad Mr. Catlett

Catlett v. Commissioner
T.C. Memo. 2021-102

On August 16, 2021, the Tax Court issued a Memorandum Opinion in the case of Catlett v. Commissioner (T.C. Memo. 2021-102). The primary issue presented in Catlett v. Commissioner was whether the IRS satisfied its burdens of production and proof to dismiss the petition for lack of prosecution…because the petitioner died…in prison…on a 17 ½ year stint in the hoosegow for tax crimes and conspiracy to defraud the United States. Background to Catlett v. Commissioner Irvin

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Scott St. Amand September 3, 2021
Income Tax Issues
Abusive Tax Shelters

Ryder & Associates Inc. v. Commissioner
T.C. Memo. 2021-88

On July 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Ryder & Associates Inc. v. Commissioner (T.C. Memo. 2021-88). The primary issues presented in Ryder & Associates Inc. v. Commissioner were whether the petitioners received unreported gross receipts from their company, and whether the petitioners had significant unreported dividend income. Author’s Note on Ryder & Associates v. Commissioner As I mentioned earlier this year, I have never seen it bode well for

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Scott St. Amand July 29, 2021
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Catlett v. Commissioner
T.C. Memo. 2021-102

On August 16, 2021, the Tax Court issued a Memorandum Opinion in the case of Catlett v. Commissioner (T.C. Memo. 2021-102). The primary issue presented in Catlett v. Commissioner was whether the IRS satisfied its burdens of production and proof to dismiss the petition for lack of prosecution…because the petitioner died…in

Read More »
Scott St. Amand September 3, 2021

Ryder & Associates Inc. v. Commissioner
T.C. Memo. 2021-88

On July 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Ryder & Associates Inc. v. Commissioner (T.C. Memo. 2021-88). The primary issues presented in Ryder & Associates Inc. v. Commissioner were whether the petitioners received unreported gross receipts from their company, and whether the petitioners had significant

Read More »
Scott St. Amand July 29, 2021