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
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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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

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