Penalties Under the Code
Dammit Felicia

Minemyer v. Commissioner
T.C. Memo. 2020-99

On July 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Minemyer v. Commissioner (T.C. Memo. 2020-99). The basic, threshold issue before the court in Minemyer v. Commissioner was whether petitioner is liable for a fraud penalty pursuant to IRC § 6663(a) for tax year 2001. Petitioner in Minemyer v. Commissioner is Not a Good Taxpayer One week prior to Tax Day in 2008, the Government filed a two-count indictment against

Read More »
Scott St. Amand July 1, 2020
Penalties Under the Code
A Petitioner Named Dung

Tran v. Commissioner
T.C. Memo. 2020-27

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran v. Commissioner were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for 2006; (2) whether the petitioners failed to report gross receipts on Schedule C (Profits or Loss From Business) with regard to their nail salons in

Read More »
Scott St. Amand February 26, 2020
Penalties Under the Code
"Penalty" Means "Penalty"

Chadwick v. Commissioner
154 T.C. No. 5

On January 21, 2020, the Tax Court issued its opinion in Chadwick v. Commissioner (154 T.C. No. 5). The issue presented in Chadwick v. Commissioner was whether the penalty assessable pursuant to IRC § 6672(a) (the Trust Fund Recovery Penalty or TFRP) was subject to the requirement that written supervisory approval be secured at the initial determination of such assessment pursuant to IRC § 6751(b)(1). The IRC § 6672(a) Trust Fund Recovery Penalty is…Wait for

Read More »
Scott St. Amand January 21, 2020
Penalties Under the Code
Badges of Fraud

Purvis v. Commissioner
T.C. Memo. 2020-13

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Purvis v. Commissioner (T.C. Memo. 2020-13). The issue presented in Purvis v. Commissioner was whether the IRS overcame their burden of proof to establish the petitioners’ liability for the taxes and the fraud penalty under IRC § 6663(a).  What a crazy case… The Quick and Dirty Background of One of the Craziest Cases I’ve Ever Read (Purvis v. Commissioner) This

Read More »
Scott St. Amand January 14, 2020
Penalties Under the Code
IRC § 6901

Alta V Limited Partnership v. Commissioner
T.C. Memo. 2020-8

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Alta V Limited Partnership v. Commissioner (T.C. Memo. 2020-8). The issue presented in Alta V Limited Partnership v. Commissioner was whether the petitioners were liable as transferees for their portion of the unpaid, determined, and assessed deficiency, penalties, and additions to tax with respect to the transferor’s corporate income tax. Transferee Liability Under the Code – IRC § 6901(a) – Alta

Read More »
Scott St. Amand January 13, 2020
Income Tax Issues
Accuracy Related Penalty

Rivera v. Commissioner
T.C. Memo. 2020-7

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions claimed on the partnership returns, and (3) the petitioners are liable for IRC § 6662(a) accuracy-related penalties.

Read More »
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

Read More »
Scott St. Amand January 6, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Minemyer v. Commissioner
T.C. Memo. 2020-99

On July 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Minemyer v. Commissioner (T.C. Memo. 2020-99). The basic, threshold issue before the court in Minemyer v. Commissioner was whether petitioner is liable for a fraud penalty pursuant to IRC § 6663(a) for tax year 2001.

Read More »
Scott St. Amand July 1, 2020

Tran v. Commissioner
T.C. Memo. 2020-27

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran v. Commissioner were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for

Read More »
Scott St. Amand February 26, 2020

Chadwick v. Commissioner
154 T.C. No. 5

On January 21, 2020, the Tax Court issued its opinion in Chadwick v. Commissioner (154 T.C. No. 5). The issue presented in Chadwick v. Commissioner was whether the penalty assessable pursuant to IRC § 6672(a) (the Trust Fund Recovery Penalty or TFRP) was subject to the requirement that written supervisory

Read More »
Scott St. Amand January 21, 2020

Purvis v. Commissioner
T.C. Memo. 2020-13

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Purvis v. Commissioner (T.C. Memo. 2020-13). The issue presented in Purvis v. Commissioner was whether the IRS overcame their burden of proof to establish the petitioners’ liability for the taxes and the fraud penalty under

Read More »
Scott St. Amand January 14, 2020

Alta V Limited Partnership v. Commissioner
T.C. Memo. 2020-8

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Alta V Limited Partnership v. Commissioner (T.C. Memo. 2020-8). The issue presented in Alta V Limited Partnership v. Commissioner was whether the petitioners were liable as transferees for their portion of the unpaid, determined, and assessed

Read More »
Scott St. Amand January 13, 2020

Rivera v. Commissioner
T.C. Memo. 2020-7

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to

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