Procedural Issues
Abuse of Discretion

Van Bemmelen v. Commissioner
155 T.C. No. 4

On August 27, 2020, the Tax Court issued its opinion in Van Bemmelen v. Commissioner(155 T.C. No. 4). The primary issue presented in Van Bemmelen v. Commissioner was whether the administrative record could be supplemented with evidence not considered by the IRS’s Whistleblower Office when it rejected the petitioner’s claim. Background to Van Bemmelen v. Commissioner In 2018, the petitioner submitted a Form 211 to the IRS’s Whistleblower Office (WBO). In this claim, the petitioner references

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Scott St. Amand August 27, 2020
Penalties Under the Code
IRC § 6751(b)(1)

Weiderman v. Commissioner
T.C. Memo. 2020-109

On July 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Weiderman v. Commissioner (T.C. Memo. 2020-109). The primary issue before the court in Weiderman v. Commissioner was whether the court should permit the reopening of the record to allow the IRS to submit evidence that it complied with the supervisory approval requirements of IRC § 6751(b)(1). Satisfying Presumption of Correctness of IRS Determination in Cases Involving Unreported Income in Weiderman

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Scott St. Amand July 15, 2020
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Van Bemmelen v. Commissioner
155 T.C. No. 4

On August 27, 2020, the Tax Court issued its opinion in Van Bemmelen v. Commissioner(155 T.C. No. 4). The primary issue presented in Van Bemmelen v. Commissioner was whether the administrative record could be supplemented with evidence not considered by the IRS’s Whistleblower Office when it rejected the petitioner’s claim. Background

Read More »
Scott St. Amand August 27, 2020

Weiderman v. Commissioner
T.C. Memo. 2020-109

On July 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Weiderman v. Commissioner (T.C. Memo. 2020-109). The primary issue before the court in Weiderman v. Commissioner was whether the court should permit the reopening of the record to allow the IRS to submit evidence that

Read More »
Scott St. Amand July 15, 2020