Income Tax Issues
Constitutional Due Process Argument

Kelley v. Commissioner
T.C. Memo. 2021-2

On January 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelley v. Commissioner (T.C. Memo. 2021-2). The issue presented in Kelley v. Commissioner was whether the provisions of IRC § 86(c) violated his Constitutional due process rights…and “various other constitutional arguments” that the Tax Court did not deign to address. Preface to Kelley v. Commissioner Anyone who has read Briefly Taxing for any length of time—you know who you are—knows

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Scott St. Amand January 11, 2021
Penalties Under the Code
"Penalty" Means "Penalty"

Laidlaw’s Harley Davidson Sales Inc. v. Commissioner
154 T.C. No. 4

On January 16, 2020, the Tax Court issued its opinion in Laidlaw’s Harley Davidson Sales Inc. v. Commissioner (154 T.C. No. 4). The issue presented in Laidlaw’s Harley Davidson Sales Inc. v. Commissioner was whether the written supervisory approval requirement of IRC § 6751(b)(1) applied to the assessable penalty imposed by IRC § 6707A (failure to disclose a reportable transaction). 30-Day Letter Triggered IRC § 6751(b)(1) Supervisory Approval Requirement in Laidlaw’s Harley Davidson Sales Inc. v. Commissioner The

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Scott St. Amand January 16, 2020
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Kelley v. Commissioner
T.C. Memo. 2021-2

On January 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelley v. Commissioner (T.C. Memo. 2021-2). The issue presented in Kelley v. Commissioner was whether the provisions of IRC § 86(c) violated his Constitutional due process rights…and “various other constitutional arguments” that the Tax Court

Read More »
Scott St. Amand January 11, 2021

Laidlaw’s Harley Davidson Sales Inc. v. Commissioner
154 T.C. No. 4

On January 16, 2020, the Tax Court issued its opinion in Laidlaw’s Harley Davidson Sales Inc. v. Commissioner (154 T.C. No. 4). The issue presented in Laidlaw’s Harley Davidson Sales Inc. v. Commissioner was whether the written supervisory approval requirement of IRC § 6751(b)(1) applied to the assessable penalty imposed by

Read More »
Scott St. Amand January 16, 2020