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
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 v. Commissioner 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. The Erroneous Zip Code Addendum in Abeuova v. Commissioner Petitioners’ five-digit ZIP Code

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Scott St. Amand June 16, 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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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

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 v. Commissioner was whether the IRS sent the notice of deficiency to the petitioners last known address, and if so, whether the

Read More »
Scott St. Amand June 16, 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