Business Related Issues
CDP

Goldberg v. Commissioner
T.C. Memo. 2021-119

On October 19, 2021, the Tax Court issued a Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2021-119). The primary issue presented in Goldberg v. Commissioner was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC § 6320 or because of his nonparticipation in an even earlier

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Scott St. Amand November 3, 2021
Business Related Issues
Abuse of Discretion

Elkins v. Commissioner
T.C. Memo. 2020-110

On July 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Elkins v. Commissioner (T.C. Memo. 2020-110). The primary issue before the court in Elkins v. Commissioner was whether Appeals abused its discretion when it sustained the rejection of the petitioner’s offer-in-compromise (OIC) on the ground that it was not in the best interest of the Government. Computational Adjustments to Partner’s Liabilities After Conclusion of Partnership-Level Proceeding in Elkins v. Commissioner

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Scott St. Amand July 16, 2020
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Goldberg v. Commissioner
T.C. Memo. 2021-119

On October 19, 2021, the Tax Court issued a Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2021-119). The primary issue presented in Goldberg v. Commissioner was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier

Read More »
Scott St. Amand November 3, 2021

Elkins v. Commissioner
T.C. Memo. 2020-110

On July 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Elkins v. Commissioner (T.C. Memo. 2020-110). The primary issue before the court in Elkins v. Commissioner was whether Appeals abused its discretion when it sustained the rejection of the petitioner’s offer-in-compromise (OIC) on the ground

Read More »
Scott St. Amand July 16, 2020