Appeals Division

Cosio v. Commissioner (T.C. Memo. 2020-90)

On June 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Cosio v. Commissioner (T.C. Memo. 2020-90). The primary issue before the court in Cosio was whether the petitioner received a reasonable opportunity to present evidence pertaining to his tax liability for 2015, when all notices sent to the petitioner referenced his 2012 liability and his right to a hearing thereupon.

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Dammit Felicia

Abeuova v. Commissioner (T.C. Memo. 2020-86)

On June 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Abeuova v. Commissioner (T.C. Memo. 2020-86). The issue before the court in Abeuova was whether the IRS sent the notice of deficiency to the petitioners last known address, and if so, whether the Tax Court has jurisdiction because of the untimely filing of the petition.

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Abuse of Discretion

Waszczuk v. Commissioner (T.C. Memo. 2020-75)

On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Waszczuk v. Commissioner (T.C. Memo. 2020-75). The issue before the court in Waszczuk was whether the IRS Whistleblower Office (WBO) abused its discretion by rejecting the petitioner’s whistleblower claim (which the WBO treated as two claims, when in reality it was one claim with an amendment by subsequent letter, which letter the WBO treated as a separate, but equally insufficient,

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Accuracy Related Penalty

McCarthy v. Commissioner (T.C. Memo. 2020-74)

On June 3, 2020, the Tax Court issued a Memorandum Opinion in the case of McCarthy v. Commissioner (T.C. Memo. 2020-74). The issues before the court in McCarthy were (1) whether the petitioner is entitled to deductions for qualified residence indebtedness with respect to real properties in New York and California, and (2) whether petitioner is liable for an accuracy-related penalty under IRC § 6662.

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Abuse of Discretion

Kirkley v. Commissioner (T.C. Memo. 2020-57)

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Kirkley v. Commissioner (T.C. Memo. 2020-57). The primary issue before the court in Kirkley was whether the IRS’s determination that petitioners must liquidate all of their property, including their residence, as a condition for the IRS’s acceptance of an installment agreement, was a (rather egregious) abuse of discretion.

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Books and Records

Keels v. Commissioner (T.C. Memo. 2020-25)

On February 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Keels v. Commissioner (T.C. Memo. 2020-25). The issues presented in Keels were (1) whether petitioner substantiated his expenses underlying his claimed deductions by maintaining adequate records, and (2) whether, because the IRS raised the application of IRC § 409A as a new basis for disallowance of the petitioner’s deductions (which had not been raised in the notice of deficiency), consequently

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Conservation Easements

Carter v. Commissioner (T.C. Memo. 2020-21)

On February 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Carter v. Commissioner (T.C. Memo. 2020-20). The issues presented in Carter were whether the restrictions contained in a conservation easement violated IRC § 170(h) and whether the IRS had satisfied the prior written supervisory approval requirement of IRC § 6751(b)(1).

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Cosio v. Commissioner (T.C. Memo. 2020-90)

On June 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Cosio v. Commissioner (T.C. Memo. 2020-90). The primary issue before the court in Cosio was whether the petitioner received a reasonable opportunity to present evidence pertaining to his tax liability for 2015, when all notices

Read More »

Abeuova v. Commissioner (T.C. Memo. 2020-86)

On June 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Abeuova v. Commissioner (T.C. Memo. 2020-86). The issue before the court in Abeuova was whether the IRS sent the notice of deficiency to the petitioners last known address, and if so, whether the Tax Court

Read More »

Waszczuk v. Commissioner (T.C. Memo. 2020-75)

On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Waszczuk v. Commissioner (T.C. Memo. 2020-75). The issue before the court in Waszczuk was whether the IRS Whistleblower Office (WBO) abused its discretion by rejecting the petitioner’s whistleblower claim (which the WBO treated as two

Read More »

McCarthy v. Commissioner (T.C. Memo. 2020-74)

On June 3, 2020, the Tax Court issued a Memorandum Opinion in the case of McCarthy v. Commissioner (T.C. Memo. 2020-74). The issues before the court in McCarthy were (1) whether the petitioner is entitled to deductions for qualified residence indebtedness with respect to real properties in New York and

Read More »

Kirkley v. Commissioner (T.C. Memo. 2020-57)

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Kirkley v. Commissioner (T.C. Memo. 2020-57). The primary issue before the court in Kirkley was whether the IRS’s determination that petitioners must liquidate all of their property, including their residence, as a condition for the

Read More »

Keels v. Commissioner (T.C. Memo. 2020-25)

On February 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Keels v. Commissioner (T.C. Memo. 2020-25). The issues presented in Keels were (1) whether petitioner substantiated his expenses underlying his claimed deductions by maintaining adequate records, and (2) whether, because the IRS raised the application

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Carter v. Commissioner (T.C. Memo. 2020-21)

On February 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Carter v. Commissioner (T.C. Memo. 2020-20). The issues presented in Carter were whether the restrictions contained in a conservation easement violated IRC § 170(h) and whether the IRS had satisfied the prior written supervisory approval

Read More »