Income Tax Issues
Deposit of Partial Payment of Liabilities

Partial Payments of Tax and Deposits with the IRS

Sunday afternoon rolls around, and the last thing on your mind was explaining the pros and cons of making partial payments of tax and deposits with the IRS to a relative who still sees “Charlie” lurking in his backyard from time to time. Nonetheless, of all of your relatives, Cousin Elmer is, surprisingly, the least offensive to you. You may remember that Elmer is currently working with only seven and a half fingers and a

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Scott St. Amand November 17, 2021
Procedural Issues
Deposit of Partial Payment of Liabilities

Hill v. Commissioner
T.C. Memo. 2021-121

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Hill v. Commissioner (T.C. Memo. 2021-121). The primary issue presented in Hill v. Commissioner was whether the petitioner’s remittance of $10.3 million to the IRS to be applied toward an anticipated gift tax liability for 2011, which remittance was designated as a “deposit” was a “deposit” or a “payment” for purposes of determining whether interest was due to the petitioner.

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Scott St. Amand November 10, 2021
Procedural Issues
Allocation of Tax Payment

Peacock v. Commissioner
T.C. Memo. 2020-63

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Peacock v. Commissioner (T.C. Memo. 2020-63). The issue before the court in Peacock v. Commissioner was whether a remittance that petitioners made to the IRS before the mailing of the notice of deficiency deprives the Tax Court of jurisdiction, which question turns on whether the remittance was in the nature of a payment or a deposit. Background to Peacock v.

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Scott St. Amand April 30, 2021
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Partial Payments of Tax and Deposits with the IRS

Sunday afternoon rolls around, and the last thing on your mind was explaining the pros and cons of making partial payments of tax and deposits with the IRS to a relative who still sees “Charlie” lurking in his backyard from time to time. Nonetheless, of all of your relatives, Cousin

Read More »
Scott St. Amand November 17, 2021

Hill v. Commissioner
T.C. Memo. 2021-121

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Hill v. Commissioner (T.C. Memo. 2021-121). The primary issue presented in Hill v. Commissioner was whether the petitioner’s remittance of $10.3 million to the IRS to be applied toward an anticipated gift tax liability for

Read More »
Scott St. Amand November 10, 2021

Peacock v. Commissioner
T.C. Memo. 2020-63

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Peacock v. Commissioner (T.C. Memo. 2020-63). The issue before the court in Peacock v. Commissioner was whether a remittance that petitioners made to the IRS before the mailing of the notice of deficiency deprives the

Read More »
Scott St. Amand April 30, 2021