Procedural Issues
Collection Due Process Hearing

Estate of Lee v. Commissioner
T.C. Memo. 2021-92

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Lee v. Commissioner (T.C. Memo. 2021-92). The primary issue presented in Estate of Lee v. Commissioner was whether the IRS abused its discretion in rejecting the petitioner’s offer-in-compromise by erring to properly compute the estate’s reasonable collection potential by including amounts distributed by the executor. Challenging the IRS Lien before Appeals in Estate of Lee v. Commissioner IRC §

Read More »
Scott St. Amand September 2, 2021
Procedural Issues
Abuse of Discretion

American Limousines Inc. v. Commissioner
T.C. Memo. 2021-36

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of American Limousines Inc. v. Commissioner (T.C. Memo. 2021-36). The primary issues presented in American Limousines Inc. v. Commissioner were whether the IRS abused its discretion in rejecting an installment agreement (that the petitioner could not fund) and whether the IRS abused its discretion in refusing to classify the petitioner’s account as currently not collectible. Background to American Limousines Inc. v. Commissioner

Read More »
Scott St. Amand March 24, 2021
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Estate of Lee v. Commissioner
T.C. Memo. 2021-92

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Lee v. Commissioner (T.C. Memo. 2021-92). The primary issue presented in Estate of Lee v. Commissioner was whether the IRS abused its discretion in rejecting the petitioner’s offer-in-compromise by erring to properly compute the

Read More »
Scott St. Amand September 2, 2021

American Limousines Inc. v. Commissioner
T.C. Memo. 2021-36

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of American Limousines Inc. v. Commissioner (T.C. Memo. 2021-36). The primary issues presented in American Limousines Inc. v. Commissioner were whether the IRS abused its discretion in rejecting an installment agreement (that the petitioner could not fund)

Read More »
Scott St. Amand March 24, 2021