Taxing, Briefly
Assessment

Statutes of Limitation on Assessment and Collection

One of the most common questions I am asked by taxpayers is “How long can the IRS try to collect my liability?” It’s a good question, and one that would seem to have a quick, easy answer. Judging purely by the length of this article, however, the answer is never as simple as it might seem. On Statutes of Limitation on Assessment and Collection With the full understanding that “It depends” is the least satisfying

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Amended Returns

Harrington v. Commissioner (T.C. Memo. 2021-95)

Harrington v. Commissioner (T.C. Memo. 2021-95) On July 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Harrington v. Commissioner (T.C. Memo. 2021-95). The primary issue presented in Harrington was whether the IRS’s assessment was assessment is barred by the three-year period of limitations in IRC § 6501(a), or whether the statute of limitations remained open due to fraud under IRC § 6501(c)(1). Summary[1] “Sarah, I feel like I don’t even

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Procedural Issues
Jurisdiction of Tax Court

Mathews v. Commissioner (T.C. Memo. 2021-85)

On July 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-85). The primary issue presented in Mathews was whether the Tax Court had jurisdiction to hear a petitioner when the pro se petitioner filed his petition (sent a letter to the Tax Court) well after the 90 day deadline had passed, and whether because the Tax Court had jurisdiction over one year’s petition, the Tax

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Procedural Issues
Adequate Disclosure

Pragias v. Commissioner (T.C. Memo. 2021-82)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Pragias v. Commissioner (T.C. Memo. 2021-82). The primary issue presented in Pragias was whether the six-year statute of limitations under IRC § 6501(e) (substantial omission of items) applied. The Substantial Omission Extension under IRC § 6501(e) IRC § 6501(a) generally requires that the IRS assess tax within three years after the taxpayer files his return. However, IRC § 6501(e), as

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Procedural Issues
Bad Debt Deductions

Kelly v. Commissioner (T.C. Memo. 2021-76)

On June 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelly v. Commissioner (T.C. Memo. 2021-76). The primary issues presented in Kelly were whether transfers from a company to the petitioner were loans, and if so, whether the petitioner received taxable distributions or cancellation of indebtedness (COD) income when the loans were cancelled. Background The petitioner was a 50% owner of Lucky Bastard Records. As of December 2007, Lucky Bastard

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Bad Mr. Bell

Bell Capital Management Inc. v. Commissioner (T.C. Memo. 2021-74)

Bell Capital Management, Inc. v. Commissioner (T.C. Memo. 2021-74) On June 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Bell Capital Management, Inc.v. Commissioner (T.C. Memo. 2021-74). The primary issues presented in Bell Capital Management, Inc. were whether (1) petitioner is collaterally estopped from denying that it was responsible for paying the employment taxes; (2) whether the IRS properly determined that Ron H. Bell should be legally classified as petitioner’s

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Procedural Issues
Books and Records

Lufkin v. Commissioner (T.C. Memo. 2021-71)

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Lufkin v. Commissioner (T.C. Memo. 2021-71). The primary issue presented in Lufkin was whether the pro se petitioner was liable for certain Form 941 liabilities. Background The IRS assessed the Form 941 liabilities, which arose in connection with the petitioner’s law practice, for the periods at issue in December 1998 and June 1999, respectively. After the petitioner underwent multiple chapter

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Statutes of Limitation on Assessment and Collection

One of the most common questions I am asked by taxpayers is “How long can the IRS try to collect my liability?” It’s a good question, and one that would seem to have a quick, easy answer. Judging purely by the length of this article, however, the answer is never

Read More »

Harrington v. Commissioner (T.C. Memo. 2021-95)

Harrington v. Commissioner (T.C. Memo. 2021-95) On July 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Harrington v. Commissioner (T.C. Memo. 2021-95). The primary issue presented in Harrington was whether the IRS’s assessment was assessment is barred by the three-year period of limitations in IRC

Read More »

Mathews v. Commissioner (T.C. Memo. 2021-85)

On July 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-85). The primary issue presented in Mathews was whether the Tax Court had jurisdiction to hear a petitioner when the pro se petitioner filed his petition (sent a letter to

Read More »

Pragias v. Commissioner (T.C. Memo. 2021-82)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Pragias v. Commissioner (T.C. Memo. 2021-82). The primary issue presented in Pragias was whether the six-year statute of limitations under IRC § 6501(e) (substantial omission of items) applied. The Substantial Omission Extension under IRC §

Read More »

Kelly v. Commissioner (T.C. Memo. 2021-76)

On June 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelly v. Commissioner (T.C. Memo. 2021-76). The primary issues presented in Kelly were whether transfers from a company to the petitioner were loans, and if so, whether the petitioner received taxable distributions or cancellation of

Read More »

Bell Capital Management Inc. v. Commissioner (T.C. Memo. 2021-74)

Bell Capital Management, Inc. v. Commissioner (T.C. Memo. 2021-74) On June 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Bell Capital Management, Inc.v. Commissioner (T.C. Memo. 2021-74). The primary issues presented in Bell Capital Management, Inc. were whether (1) petitioner is collaterally estopped from denying

Read More »

Lufkin v. Commissioner (T.C. Memo. 2021-71)

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Lufkin v. Commissioner (T.C. Memo. 2021-71). The primary issue presented in Lufkin was whether the pro se petitioner was liable for certain Form 941 liabilities. Background The IRS assessed the Form 941 liabilities, which arose

Read More »