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
Procedural Issues
Example of a Taxpayer Dragging His Ass

Thomas v. Commissioner
T.C. Memo. 2020-33

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Thomas v. Commissioner (T.C. Memo. 2020-33). The single issue presented in Thomas v. Commissioner was whether the petitioners timely filed their petition within the time prescribed by IRC § 6213(a) or IRC § 7502, which in turn depended on whether a private postmark bearing a previous date to the USPS postmark was controlling. Background to Thomas v. Commissioner In November

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Scott St. Amand March 5, 2020
Procedural Issues
Deadlines for Filing

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which the petition was mailed bore no postmark. If so, then the Tax Court had jurisdiction to redetermine the deficiency.  If not, then no jurisdiction would

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Scott St. Amand January 13, 2020
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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

Thomas v. Commissioner
T.C. Memo. 2020-33

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Thomas v. Commissioner (T.C. Memo. 2020-33). The single issue presented in Thomas v. Commissioner was whether the petitioners timely filed their petition within the time prescribed by IRC § 6213(a) or IRC § 7502, which

Read More »
Scott St. Amand March 5, 2020

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which

Read More »
Scott St. Amand January 13, 2020