Income Tax Issues
Divorce

Leith v. Commissioner
T.C. Memo. 2020-149

On November 4, 2020, the Tax Court issued a Memorandum Opinion in the case Leith v. Commissioner (T.C. Memo. 2020-149). The primary issue before the court in Leith v. Commissioner was whether the petitioner is entitled to IRC § 6015(f) equitable innocent spouse relief to the extent of the tax items attributable to her ex-husband for the years at issue, even though her ex-husband (the intervenor) opposed the relief.

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Scott St. Amand November 4, 2020
Adverse Determination of Charitable Status

The Korean American Senior Mutual Assoc. Inc. v. Commissioner
T.C. Memo. 2020-129

On September 9, 2020, the Tax Court issued a Memorandum Opinion in the case of The Korean American Senior Mutual Assoc. Inc. v. Commissioner (T.C. Memo. 2020-129). The primary issue before the court in Korean-American was whether The Korean-American Senior Mutual Association, Inc. (KASMA) was operated exclusively for one or more exempt purposes as set forth in IRC § 501(c)(3). Background to The Korean American Senior Mutual Assoc. Inc. v. Commissioner The Korean-American Senior Mutual

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Scott St. Amand September 9, 2020
Procedural Issues
Abuse of Discretion

Whistleblower 21276-13W v. Commissioner
155 T.C. No. 2

On August 26, 2020, the Tax Court issued its opinion in Whistleblower 21276-13W v. Commissioner (155 T.C. No. 2). The primary issue presented in Whistleblower 21276-13W v. Commissioner was whether the Tax Court had jurisdiction to hear and determine a whistleblower-related issue rather than remand it to the IRS Whistleblower Office when remand would have been futile because there was only one possible disposition, as a matter of law, and such matter was before the court.

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Scott St. Amand August 26, 2020
Income Tax Issues
Collection Alternatives

Swanberg v. Commissioner
T.C. Memo. 2020-123

On August 25, 2020, the Tax Court issued a Memorandum Opinion in the case of Swanberg v. Commissioner (T.C. Memo. 2020-123). The primary issue before the court in Swanberg v. Commissioner was whether the IRS abused its discretion in failing to consider the petitioner’s prior year credits in determining liability for the year under examination. Availability of Credit in Swanberg v. Commissioner If your client’s primary argument to avoid liability in year at issue is

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Scott St. Amand August 25, 2020
Business Related Issues
Computational Adjustment

Stevens v. Commissioner
T.C. Memo. 2020-118

On August 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Stevens v. Commissioner (T.C. Memo. 2020-118). The primary issue before the court in Stevens v. Commissioner was whether (and to the what extent) the Tax Court can uphold the IRS’s deficiencies in the face of the petitioners’ claimed partnership loss deductions. The decision of this broad issue hinges on three primary sub-issues, which are whether (1) three partnerships were “small

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Scott St. Amand August 6, 2020
Business Related Issues
§ 530 of the Revenue Act of 1978

Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114)

On August 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114). The primary issue before the court in Reflectxion Resources Inc. v. Commissioner was whether the Tax Court has jurisdiction to determine whether the petitioner was entitled to relief from worker classification liabilities pursuant to § 530 of the Revenue Act of 1978. Background to Reflectxion Resources Inc. v. Commissioner The petitioner was as

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Scott St. Amand August 3, 2020
Procedural Issues
CDP

Ruesch v. Commissioner (154 T.C. No. 13)

On June 25, 2020, the Tax Court issued its opinion in Ruesch v. Commissioner (154 T.C. No. 13). The two issues in Ruesch v. Commissioner were (1) whether the Tax Court possessed jurisdiction under IRC § 7345(b) to consider the petitioner’s challenge to her underlying tax debts; and (2) whether the Tax Court possessed jurisdiction to review the petitioner’s challenge to the IRS’s certification of the petitioner’s liabilities as “seriously delinquent pursuant to IRC §

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Scott St. Amand June 25, 2020
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Leith v. Commissioner
T.C. Memo. 2020-149

On November 4, 2020, the Tax Court issued a Memorandum Opinion in the case Leith v. Commissioner (T.C. Memo. 2020-149). The primary issue before the court in Leith v. Commissioner was whether the petitioner is entitled to IRC § 6015(f) equitable innocent spouse relief to the extent of the tax

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Scott St. Amand November 4, 2020

Whistleblower 21276-13W v. Commissioner
155 T.C. No. 2

On August 26, 2020, the Tax Court issued its opinion in Whistleblower 21276-13W v. Commissioner (155 T.C. No. 2). The primary issue presented in Whistleblower 21276-13W v. Commissioner was whether the Tax Court had jurisdiction to hear and determine a whistleblower-related issue rather than remand it to the IRS Whistleblower Office

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Scott St. Amand August 26, 2020

Swanberg v. Commissioner
T.C. Memo. 2020-123

On August 25, 2020, the Tax Court issued a Memorandum Opinion in the case of Swanberg v. Commissioner (T.C. Memo. 2020-123). The primary issue before the court in Swanberg v. Commissioner was whether the IRS abused its discretion in failing to consider the petitioner’s prior year credits in determining liability

Read More »
Scott St. Amand August 25, 2020

Stevens v. Commissioner
T.C. Memo. 2020-118

On August 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Stevens v. Commissioner (T.C. Memo. 2020-118). The primary issue before the court in Stevens v. Commissioner was whether (and to the what extent) the Tax Court can uphold the IRS’s deficiencies in the face of

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Scott St. Amand August 6, 2020

Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114)

On August 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114). The primary issue before the court in Reflectxion Resources Inc. v. Commissioner was whether the Tax Court has jurisdiction to determine whether the petitioner was entitled to relief

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Scott St. Amand August 3, 2020

Ruesch v. Commissioner (154 T.C. No. 13)

On June 25, 2020, the Tax Court issued its opinion in Ruesch v. Commissioner (154 T.C. No. 13). The two issues in Ruesch v. Commissioner were (1) whether the Tax Court possessed jurisdiction under IRC § 7345(b) to consider the petitioner’s challenge to her underlying tax debts; and (2) whether

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Scott St. Amand June 25, 2020