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
Procedural Issues
A Petitioner Named Do-Wong

Wong v. Commissioner
T.C. Memo. 2020-32

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Wong v. Commissioner (T.C. Memo. 2020-32). The single issue presented in Wong v. Commissioner was whether Wong was right, which is to say, whether the IRS’s determination to sustain the collection action against the petitioner was proper as a matter of law. Background to Wong v. Commissioner Petitioner, Do Wong, filed a timely Federal income tax return for 2013, reporting

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Scott St. Amand March 5, 2020
Procedural Issues
Deficiency Proceeding

Liu v. Commissioner
T.C. Memo. 2020-31

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Liu v. Commissioner (T.C. Memo. 2020-31). The single issue presented in Liu v. Commissioner was whether the Tax Court had jurisdiction to determine whether petitioners were liable for interest on the deficiencies determined by the IRS because the IRS filed an erroneous notice of Federal tax lien (NFTL). Background to Liu v. Commissioner Petitioners each owned a 50% interest in

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Scott St. Amand March 5, 2020
Penalties Under the Code
Assessable Penalties

Sun River Financial Trust v. Commissioner
T.C. Memo. 2020-30

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Sun River Financial Trust v. Commissioner (T.C. Memo. 2020-30). The single issue presented in Sun River Financial Trust v. Commissioner was whether the IRS abused its discretion in sustaining a proposed levy and the filing of a notice of Federal tax lien (NFTL) with respect to petitioner’s unpaid IRC § 6702 (frivolous return) penalties for 2010 and 2011. Background to Sun

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Scott St. Amand March 5, 2020
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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

Wong v. Commissioner
T.C. Memo. 2020-32

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Wong v. Commissioner (T.C. Memo. 2020-32). The single issue presented in Wong v. Commissioner was whether Wong was right, which is to say, whether the IRS’s determination to sustain the collection action against the petitioner

Read More »
Scott St. Amand March 5, 2020

Liu v. Commissioner
T.C. Memo. 2020-31

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Liu v. Commissioner (T.C. Memo. 2020-31). The single issue presented in Liu v. Commissioner was whether the Tax Court had jurisdiction to determine whether petitioners were liable for interest on the deficiencies determined by the

Read More »
Scott St. Amand March 5, 2020

Sun River Financial Trust v. Commissioner
T.C. Memo. 2020-30

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Sun River Financial Trust v. Commissioner (T.C. Memo. 2020-30). The single issue presented in Sun River Financial Trust v. Commissioner was whether the IRS abused its discretion in sustaining a proposed levy and the filing of

Read More »
Scott St. Amand March 5, 2020