Income Tax Issues
Collection Due Process Hearing

Savedoff v. Commissioner
T.C. Memo. 2020-125

On August 31, 2020, the Tax Court issued a Memorandum Opinion in the case of Savedoff v. Commissioner (T.C. Memo. 2020-125). The primary issues before the court in Savedoff were whether the petitioner received proper notice of the Notice of Federal Tax Lien filing and whether the IRS abused its discretion in its ultimate determination against the petitioner. Background to Savedoff v. Commissioner The petitioner is a self-employed attorney. Although she filed income tax returns

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Scott St. Amand August 31, 2020
Procedural Issues
Challenging Underlying Liability

Nguyen v. Commissioner
T.C. Memo. 2020-96

On June 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Nguyen v. Commissioner (T.C. Memo. 2020-96). The basic, threshold issue before the court in Nguyen v. Commissioner was whether the petitioner may challenge his underlying liability in the Tax Court. Brief Background to Nguyen v. Commissioner the IRS sent, by certified mail, a notice of deficiency for the years in issue to the petitioner at his last-known address. The notice

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Scott St. Amand June 30, 2020
Procedural Issues
Burden of Proof

Lander v. Commissioner
154 T.C. No. 7

On March 12, 2020, the Tax Court issued its opinion in Lander v. Commissioner (154 T.C. No. 7). The issue presented in Lander v. Commissioner was whether the petitioners, who did not receive the statutory notice of deficiency (SNOD) mailed to their last known address, could challenge their underlying tax liability in a collection due process (CDP) proceeding. Public Service Announcement from Lander v. Commissioner You may have come to this post because you are

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Scott St. Amand March 12, 2020
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Savedoff v. Commissioner
T.C. Memo. 2020-125

On August 31, 2020, the Tax Court issued a Memorandum Opinion in the case of Savedoff v. Commissioner (T.C. Memo. 2020-125). The primary issues before the court in Savedoff were whether the petitioner received proper notice of the Notice of Federal Tax Lien filing and whether the IRS abused its

Read More »
Scott St. Amand August 31, 2020

Nguyen v. Commissioner
T.C. Memo. 2020-96

On June 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Nguyen v. Commissioner (T.C. Memo. 2020-96). The basic, threshold issue before the court in Nguyen v. Commissioner was whether the petitioner may challenge his underlying liability in the Tax Court. Brief Background to Nguyen v.

Read More »
Scott St. Amand June 30, 2020

Lander v. Commissioner
154 T.C. No. 7

On March 12, 2020, the Tax Court issued its opinion in Lander v. Commissioner (154 T.C. No. 7). The issue presented in Lander v. Commissioner was whether the petitioners, who did not receive the statutory notice of deficiency (SNOD) mailed to their last known address, could challenge their underlying tax

Read More »
Scott St. Amand March 12, 2020