Procedural Issues
Cash Bond

Ahmed v. Commissioner
T.C. Memo. 2021-142

On December 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Ahmed v. Commissioner (T.C. Memo. 2021-142). The primary issue presented in Ahmed was whether the taxpayer’s payment of all monies owed mooted his challenge to the IRS’s imposition of a lien and the trust fund recovery penalty (“TFRP”). Held: Yup. Background to Ahmed v. Commissioner In June 2020, the petitioner sent to the IRS a check for $625,000 along with

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Scott St. Amand April 28, 2022
Procedural Issues
Allocation of Tax Payment

Peacock v. Commissioner
T.C. Memo. 2020-63

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Peacock v. Commissioner (T.C. Memo. 2020-63). The issue before the court in Peacock v. Commissioner was whether a remittance that petitioners made to the IRS before the mailing of the notice of deficiency deprives the Tax Court of jurisdiction, which question turns on whether the remittance was in the nature of a payment or a deposit. Background to Peacock v.

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Scott St. Amand April 30, 2021
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Ahmed v. Commissioner
T.C. Memo. 2021-142

On December 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Ahmed v. Commissioner (T.C. Memo. 2021-142). The primary issue presented in Ahmed was whether the taxpayer’s payment of all monies owed mooted his challenge to the IRS’s imposition of a lien and the trust fund

Read More »
Scott St. Amand April 28, 2022

Peacock v. Commissioner
T.C. Memo. 2020-63

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Peacock v. Commissioner (T.C. Memo. 2020-63). The issue before the court in Peacock v. Commissioner was whether a remittance that petitioners made to the IRS before the mailing of the notice of deficiency deprives the

Read More »
Scott St. Amand April 30, 2021