International Issues
Certification of Seriously Delinquent Tax Debt

Kaebel v. Commissioner
T.C. Memo. 2021-109

On September 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Kaebel v. Commissioner (T.C. Memo. 2021-109). The primary issues presented in Kaebel v. Commissioner were (a) whether the petitioner was precluded from arguing that the IRS did not send him deficiency notices; (b) whether the IRS erred in certifying that the petitioner had seriously delinquent tax debt; and (c) whether the petitioner should be sanctioned for advancing the groundless argument that

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Scott St. Amand October 8, 2021
International Issues
Passport

Garcia v. Commissioner
157 T.C. No. 1

On July 19, 2021, the Tax Court issued its opinion in Garcia v. Commissioner (157 T.C. No. 1). The primary issues presented in Garcia v. Commissioner were whether the petition to reverse the certification of a seriously delinquent tax debt was mooted by the actual reversal and whether the Tax Court had jurisdiction in a passport certification case to determine whether the rejection of a collection alternative was in error. Background of Certification Statute in Garcia

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Scott St. Amand August 31, 2021
Taxing, Briefly
Bankruptcy

Taxing, Briefly – Can the IRS Take My Passport?

When my son was two, his grandmother gave him a stuffed owl. Not a particularly creative toddler, he named the little owl Stuffy, and the name has stuck to this day.  What does this have to do with the question “Can the IRS Take My Passport?”  Patience…all will be revealed. He took the owl everywhere, which naturally led to many a calamity when Stuffy was inevitably misplaced. For my wife and I, Stuffy also had an

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Scott St. Amand June 7, 2021
Procedural Issues
IRC § 7345

Shitrit v. Commissioner
T.C. Memo. 2021-63

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Shitrit v. Commissioner (T.C. Memo. 2021-63). The primary issue presented in Shitrit v. Commissioner was whether the Tax Court had jurisdiction to entertain the suit subsequent to the IRS’s concession that its certification of the petitioner’s tax debt as “seriously delinquent” was erroneous. Background to Shitrit v. Commissioner Mr. Uriah Shitrit is a dual citizen of Israel and the United States.

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Scott St. Amand May 26, 2021
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
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Kaebel v. Commissioner
T.C. Memo. 2021-109

On September 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Kaebel v. Commissioner (T.C. Memo. 2021-109). The primary issues presented in Kaebel v. Commissioner were (a) whether the petitioner was precluded from arguing that the IRS did not send him deficiency notices; (b) whether the IRS

Read More »
Scott St. Amand October 8, 2021

Garcia v. Commissioner
157 T.C. No. 1

On July 19, 2021, the Tax Court issued its opinion in Garcia v. Commissioner (157 T.C. No. 1). The primary issues presented in Garcia v. Commissioner were whether the petition to reverse the certification of a seriously delinquent tax debt was mooted by the actual reversal and whether the Tax

Read More »
Scott St. Amand August 31, 2021

Taxing, Briefly – Can the IRS Take My Passport?

When my son was two, his grandmother gave him a stuffed owl. Not a particularly creative toddler, he named the little owl Stuffy, and the name has stuck to this day.  What does this have to do with the question “Can the IRS Take My Passport?”  Patience…all will be revealed. He

Read More »
Scott St. Amand June 7, 2021

Shitrit v. Commissioner
T.C. Memo. 2021-63

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Shitrit v. Commissioner (T.C. Memo. 2021-63). The primary issue presented in Shitrit v. Commissioner was whether the Tax Court had jurisdiction to entertain the suit subsequent to the IRS’s concession that its certification of the petitioner’s

Read More »
Scott St. Amand May 26, 2021

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