Procedural Issues
CDP

Ruesch v. Commissioner (154 T.C. No. 13)

On June 25, 2020, the Tax Court issued its opinion in Ruesch v. Commissioner (154 T.C. No. 13). The two issues in Ruesch v. Commissioner were (1) whether the Tax Court possessed jurisdiction under IRC § 7345(b) to consider the petitioner’s challenge to her underlying tax debts; and (2) whether the Tax Court possessed jurisdiction to review the petitioner’s challenge to the IRS’s certification of the petitioner’s liabilities as “seriously delinquent pursuant to IRC §

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Scott St. Amand June 25, 2020
Procedural Issues
Jurisdiction of Tax Court

Lord Pope v. Commissioner
T.C. Memo. 2020-62

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Pope v. Commissioner (T.C. Memo. 2020-62). The basic issue before the court in Pope was whether the Tax Court lacks jurisdiction to redetermine a deficiency under IRC § 6213(a) when no deficiency was determined but which determination reduces the petitioners’ claimed entitlement to a refund. Background to Pope v. Commissioner Nothing against Judge Lauber – I genuinely appreciate his no

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Scott St. Amand May 18, 2020
Income Tax Issues
Jurisdiction of Tax Court

Staples v. Commissioner
T.C. Memo. 2020-34

On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount he received as Social Security Disability Insurance (SSDI) benefits. Background to Staples v. Commissioner The petitioner worked for the USPTO until disability forced him to

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Scott St. Amand March 11, 2020
Business Related Issues
Adjustments

Manroe v. Commissioner
T.C. Memo. 2020-16

On January 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Manroe v. Commissioner (T.C. Memo. 2020-16). The issue presented in Manroe v. Commissioner was whether the Tax Court had jurisdiction over the partners to redetermine the penalties at issue in a partner-level proceeding. Background to Manroe v. Commissioner The case stems from a tax shelter transaction, in which the petitioners ultimately conceded that the partnership at issue was a sham,

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Scott St. Amand January 22, 2020
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Ruesch v. Commissioner (154 T.C. No. 13)

On June 25, 2020, the Tax Court issued its opinion in Ruesch v. Commissioner (154 T.C. No. 13). The two issues in Ruesch v. Commissioner were (1) whether the Tax Court possessed jurisdiction under IRC § 7345(b) to consider the petitioner’s challenge to her underlying tax debts; and (2) whether

Read More »
Scott St. Amand June 25, 2020

Lord Pope v. Commissioner
T.C. Memo. 2020-62

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Pope v. Commissioner (T.C. Memo. 2020-62). The basic issue before the court in Pope was whether the Tax Court lacks jurisdiction to redetermine a deficiency under IRC § 6213(a) when no deficiency was determined but

Read More »
Scott St. Amand May 18, 2020

Staples v. Commissioner
T.C. Memo. 2020-34

On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount

Read More »
Scott St. Amand March 11, 2020

Manroe v. Commissioner
T.C. Memo. 2020-16

On January 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Manroe v. Commissioner (T.C. Memo. 2020-16). The issue presented in Manroe v. Commissioner was whether the Tax Court had jurisdiction over the partners to redetermine the penalties at issue in a partner-level proceeding. Background to

Read More »
Scott St. Amand January 22, 2020