Procedural Issues
IRC § 7345

Shitrit v. Commissioner
T.C. Memo. 2021-63

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Shitrit v. Commissioner (T.C. Memo. 2021-63). The primary issue presented in Shitrit v. Commissioner was whether the Tax Court had jurisdiction to entertain the suit subsequent to the IRS’s concession that its certification of the petitioner’s tax debt as “seriously delinquent” was erroneous. Background to Shitrit v. Commissioner Mr. Uriah Shitrit is a dual citizen of Israel and the United States.

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Scott St. Amand May 26, 2021
Procedural Issues
Bad Taxpayer

Rowen v. Commissioner
156 T.C. No. 8

On March 30, 2021, the Tax Court issued its opinion in Rowen v. Commissioner, 156 T.C. No. 8. The underlying issue presented in Rowen v. Commissionerwas whether the IRS’s certification of the petitioner’s tax debt as “seriously delinquent” violated the Fifth Amendment and his basic human rights, because it infringed on his right to international travel. Background to Rowen v. Commissioner For more than two decades the petitioner avoided paying his taxes.  The opinion notes

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Scott St. Amand March 30, 2021
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Shitrit v. Commissioner
T.C. Memo. 2021-63

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Shitrit v. Commissioner (T.C. Memo. 2021-63). The primary issue presented in Shitrit v. Commissioner was whether the Tax Court had jurisdiction to entertain the suit subsequent to the IRS’s concession that its certification of the petitioner’s

Read More »
Scott St. Amand May 26, 2021

Rowen v. Commissioner
156 T.C. No. 8

On March 30, 2021, the Tax Court issued its opinion in Rowen v. Commissioner, 156 T.C. No. 8. The underlying issue presented in Rowen v. Commissionerwas whether the IRS’s certification of the petitioner’s tax debt as “seriously delinquent” violated the Fifth Amendment and his basic human rights, because it infringed

Read More »
Scott St. Amand March 30, 2021