Procedural Issues
Form 8857

Lewis v. Commissioner
158 T.C. No. 3

On March 3, 2022, the Tax Court issued the full opinion in Lewis v. Commissioner (158 T.C. No. 3). The primary issues presented in Lewis v. Commissioner were (i) whether the letter that the taxpayer sent to the IRS constituted a “qualified offer” (sorry, Gina, but no) and (ii) whether the IRS’s position in the litigation was “substantially justified” (don’t quit your job at the diner, because the position was justified…substantially). Lewis v. Commissioner in

Read More »
Procedural Issues
Administrative Costs

Morreale v. Commissioner
T.C. Memo. 2021-90

On July 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Morreale v. Commissioner (T.C. Memo. 2021-90). The primary issue presented in Morreale v. Commissioner was whether the petitioner was entitled for reasonable litigation fees from the IRS. Background to Morreale v. Commissioner The petitioner filed a Tax Court petition in November 2017 disputing certain adjustments to his return. The petitioner and the IRS settled in January 2019, with the IRS

Read More »
Procedural Issues
Dismissal of Tax Court Petition

Stein v. Commissioner
156 T.C. No. 11

On June 17, 2021, the Tax Court issued its opinion in Stein v. Commissioner (156 T.C. No. 11). The primary issue presented in Stein v. Commissioner was whether the Tax Court has discretion to grant the petitioners’ motion to dismiss a stand-alone petition for recovery of administrative costs when the petition did not invoke the Tax Court’s jurisdiction to redetermine a deficiency under IRC § 6213(a). Factual Background in Stein v. Commissioner The petitioners filed an

Read More »
Procedural Issues
Burden of Proof

Jacobs v. Commissioner
T.C. Memo. 2021-51

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Jacobs v. Commissioner (T.C. Memo. 2021-51). The primary issue presented in Jacobs v. Commissioner was whether the petitioner was entitled to reasonable litigation and administrative costs pursuant to IRC § 7430 and Tax Court Rule 231. A Lawyer, Scholar, and Author in Jacobs v. Commissioner The petitioner was a trial lawyer with the Department of Justice for 20 years before

Read More »
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Lewis v. Commissioner
158 T.C. No. 3

On March 3, 2022, the Tax Court issued the full opinion in Lewis v. Commissioner (158 T.C. No. 3). The primary issues presented in Lewis v. Commissioner were (i) whether the letter that the taxpayer sent to the IRS constituted a “qualified offer” (sorry, Gina, but no) and (ii) whether

Read More »

Morreale v. Commissioner
T.C. Memo. 2021-90

On July 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Morreale v. Commissioner (T.C. Memo. 2021-90). The primary issue presented in Morreale v. Commissioner was whether the petitioner was entitled for reasonable litigation fees from the IRS. Background to Morreale v. Commissioner The petitioner filed

Read More »

Stein v. Commissioner
156 T.C. No. 11

On June 17, 2021, the Tax Court issued its opinion in Stein v. Commissioner (156 T.C. No. 11). The primary issue presented in Stein v. Commissioner was whether the Tax Court has discretion to grant the petitioners’ motion to dismiss a stand-alone petition for recovery of administrative costs when the petition

Read More »

Jacobs v. Commissioner
T.C. Memo. 2021-51

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Jacobs v. Commissioner (T.C. Memo. 2021-51). The primary issue presented in Jacobs v. Commissioner was whether the petitioner was entitled to reasonable litigation and administrative costs pursuant to IRC § 7430 and Tax Court Rule

Read More »