Penalties Under the Code
Challenging Levy

Kazmi v. Commissioner
T.C. Memo. 2022-13

On March 1, 2022, the Tax Court issued a Memorandum Opinion in the case of Kazmi v. Commissioner (T.C. Memo. 2022-13). The primary issues presented in Kazmi v. Commissioner were (1) whether the petitioner is entitled to challenge the underlying liabilities, and if so, whether he is a responsible person who willfully failed to pay over employment taxes under IRC § 6672, and (2) whether the Appeals abused its discretion in sustaining the collection action.

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Scott St. Amand May 20, 2022
Procedural Issues
Abuse of Discretion

Bunton v. Commissioner
T.C. Memo. 2021-141

On December 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Bunton v. Commissioner (T.C. Memo. 2021-141). The primary issue presented in Bunton was whether the IRS office of Appeals abused its discretion by sustaining a levy upon the taxpayers’ (read: tax protesters) state tax refund. Held: Not so much. Background to Bunton v. Commissioner The petitioners are tax protesters, who adopted the good ol’ “we’re not federal workers or them

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Scott St. Amand April 27, 2022
Penalties Under the Code
Challenging Underlying Liability

Cashaw v. Commissioner
T.C. Memo. 2021-123

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Cashaw v. Commissioner (T.C. Memo. 2021-123). The primary issue presented in Cashaw v. Commissioner was whether the petitioner is liable for trust fund recovery penalties. Held: Yup. Background to Cashaw v. Commissioner The petitioner was presented with difficult choices during her tenure as temporary chief administrator of a hospital. The hospital was under a state order freezing its bank accounts

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Scott St. Amand November 12, 2021
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Kazmi v. Commissioner
T.C. Memo. 2022-13

On March 1, 2022, the Tax Court issued a Memorandum Opinion in the case of Kazmi v. Commissioner (T.C. Memo. 2022-13). The primary issues presented in Kazmi v. Commissioner were (1) whether the petitioner is entitled to challenge the underlying liabilities, and if so, whether he is a responsible person

Read More »
Scott St. Amand May 20, 2022

Bunton v. Commissioner
T.C. Memo. 2021-141

On December 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Bunton v. Commissioner (T.C. Memo. 2021-141). The primary issue presented in Bunton was whether the IRS office of Appeals abused its discretion by sustaining a levy upon the taxpayers’ (read: tax protesters) state tax refund.

Read More »
Scott St. Amand April 27, 2022

Cashaw v. Commissioner
T.C. Memo. 2021-123

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Cashaw v. Commissioner (T.C. Memo. 2021-123). The primary issue presented in Cashaw v. Commissioner was whether the petitioner is liable for trust fund recovery penalties. Held: Yup. Background to Cashaw v. Commissioner The petitioner was

Read More »
Scott St. Amand November 12, 2021