Penalties Under the Code
Failure to File Penalty

Morris v. Commissioner
T.C. Memo. 2021-120

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Morris v. Commissioner (T.C. Memo. 2021-120). The primary issue presented in Morris v. Commissioner was whether the petitioner’s or liable for penalties for failure to timely file (IRC § 6651(a)(1)), failure to timely pay (IRC § 6651(a)(2)), and failure to pay estimated tax (IRC § 6654). Held: Yes. Yes, they were. Background to Morris v. Commissioner Mr. Morris was a

Read More »
Scott St. Amand November 8, 2021
Procedural Issues
Abuse of Discretion

Abraham v. Commissioner
T.C. Memo. 2021-97

On August 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Abraham v. Commissioner (T.C. Memo. 2021-97). The primary issue presented in Abraham v. Commissioner  was whether the settlement officer abused its discretion in rejecting the petitioners’ offer in compromise and by not performing a bankruptcy analysis. Initial Observations about Abraham v. Commissioner Father Abraham three wives—Hagar, Sarah, and Keteurah. Jerry Abraham had one wife. Her name was Debra. The Returns

Read More »
Scott St. Amand September 27, 2021
Penalties Under the Code
Burden of Proof

Frost v. Commissioner
154 T.C. No. 2

On January 7, 2020, the Tax Court issued its opinion in Frost v. Commissioner (154 T.C. No. 2). The issue presented in Frost v. Commissioner was whether the IRS satisfied the burden of production under IRC § 7491(c) in offering evidence of compliance with the requirement of IRC § 6751(b)(1) that the agent initially determining accuracy-related penalties obtained timely written supervisory approval to assert IRC § 6662(a) accuracy-related penalties against the petitioner. Parsing the Semantics

Read More »
Scott St. Amand January 7, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Morris v. Commissioner
T.C. Memo. 2021-120

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Morris v. Commissioner (T.C. Memo. 2021-120). The primary issue presented in Morris v. Commissioner was whether the petitioner’s or liable for penalties for failure to timely file (IRC § 6651(a)(1)), failure to timely pay (IRC

Read More »
Scott St. Amand November 8, 2021

Abraham v. Commissioner
T.C. Memo. 2021-97

On August 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Abraham v. Commissioner (T.C. Memo. 2021-97). The primary issue presented in Abraham v. Commissioner  was whether the settlement officer abused its discretion in rejecting the petitioners’ offer in compromise and by not performing a bankruptcy

Read More »
Scott St. Amand September 27, 2021

Frost v. Commissioner
154 T.C. No. 2

On January 7, 2020, the Tax Court issued its opinion in Frost v. Commissioner (154 T.C. No. 2). The issue presented in Frost v. Commissioner was whether the IRS satisfied the burden of production under IRC § 7491(c) in offering evidence of compliance with the requirement of IRC § 6751(b)(1)

Read More »
Scott St. Amand January 7, 2020