Business Related Issues
Adjustments

Manroe v. Commissioner
T.C. Memo. 2020-16

On January 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Manroe v. Commissioner (T.C. Memo. 2020-16). The issue presented in Manroe v. Commissioner was whether the Tax Court had jurisdiction over the partners to redetermine the penalties at issue in a partner-level proceeding. Background to Manroe v. Commissioner The case stems from a tax shelter transaction, in which the petitioners ultimately conceded that the partnership at issue was a sham,

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Scott St. Amand January 22, 2020
Procedural Issues
Deadlines for Filing

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which the petition was mailed bore no postmark. If so, then the Tax Court had jurisdiction to redetermine the deficiency.  If not, then no jurisdiction would

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Scott St. Amand January 13, 2020
Procedural Issues
Burden of Proof

Chicago Baseball Holdings LLC v. Commissioner
T.C. Memo. 2020-2

On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Chicago Baseball Holdings LLC v. Commissioner (T.C. Memo. 2020-2). The issue presented in Chicago Baseball Holdings LLC v. Commissioner was whether prior written supervisory approval of penalties was required before the IRS communicates the penalties to the taxpayer for the first time, even if such communication was informal. Jurisdiction in Chicago Baseball Holdings LLC v. Commissioner The Tax Court has jurisdiction

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Scott St. Amand January 6, 2020
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Manroe v. Commissioner
T.C. Memo. 2020-16

On January 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Manroe v. Commissioner (T.C. Memo. 2020-16). The issue presented in Manroe v. Commissioner was whether the Tax Court had jurisdiction over the partners to redetermine the penalties at issue in a partner-level proceeding. Background to

Read More »
Scott St. Amand January 22, 2020

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which

Read More »
Scott St. Amand January 13, 2020

Chicago Baseball Holdings LLC v. Commissioner
T.C. Memo. 2020-2

On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Chicago Baseball Holdings LLC v. Commissioner (T.C. Memo. 2020-2). The issue presented in Chicago Baseball Holdings LLC v. Commissioner was whether prior written supervisory approval of penalties was required before the IRS communicates the penalties to

Read More »
Scott St. Amand January 6, 2020