Procedural Issues
Assignment of Error

Larkin v. Commissioner (T.C. Memo. 2020-70)

On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Larkin v. Commissioner (T.C. Memo. 2020-70). The underlying issue before the court in Larkin v. Commissioner was whether the petitioners provided substantial, credible evidence to support their deductions claimed on their returns for the years at issue. Although there are a number of sub-issues, the entry of arguments and evidence into the record through pleading and briefs is the primary

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Scott St. Amand May 28, 2020
Procedural Issues
Deficiency Proceeding

Liu v. Commissioner
T.C. Memo. 2020-31

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Liu v. Commissioner (T.C. Memo. 2020-31). The single issue presented in Liu v. Commissioner was whether the Tax Court had jurisdiction to determine whether petitioners were liable for interest on the deficiencies determined by the IRS because the IRS filed an erroneous notice of Federal tax lien (NFTL). Background to Liu v. Commissioner Petitioners each owned a 50% interest in

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Scott St. Amand March 5, 2020
Procedural Issues
Deadlines for Filing

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which the petition was mailed bore no postmark. If so, then the Tax Court had jurisdiction to redetermine the deficiency.  If not, then no jurisdiction would

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Scott St. Amand January 13, 2020
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Larkin v. Commissioner (T.C. Memo. 2020-70)

On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Larkin v. Commissioner (T.C. Memo. 2020-70). The underlying issue before the court in Larkin v. Commissioner was whether the petitioners provided substantial, credible evidence to support their deductions claimed on their returns for the years

Read More »
Scott St. Amand May 28, 2020

Liu v. Commissioner
T.C. Memo. 2020-31

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Liu v. Commissioner (T.C. Memo. 2020-31). The single issue presented in Liu v. Commissioner was whether the Tax Court had jurisdiction to determine whether petitioners were liable for interest on the deficiencies determined by the

Read More »
Scott St. Amand March 5, 2020

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which

Read More »
Scott St. Amand January 13, 2020