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