Burden of Proof

Frost v. Commissioner (154 T.C. No. 2)

On January 7, 2020, the Tax Court issued its opinion in Frost v. Commissioner, 154 T.C. No. 2. The issue presented in Frost was whether the IRS satisfied the burden of production under IRC § 7491(c) in offering evidence of compliance with the requirement of IRC § 6751(b)(1) that the agent initially determining accuracy-related penalties obtained timely written supervisory approval to assert IRC § 6662(a) accuracy-related penalties against the petitioner. Parsing the Semantics: Burden of

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Admissibility of Evidence

Grieve v. Commissioner (T.C. Memo. 2020-28)

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to the petitioner from a GRAT and an irrevocable trust, respectively.

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Burden of Proof

Isaacson v. Commissioner (T.C. Memo. 2020-17)

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Isaacson v. Commissioner (T.C. Memo. 2020-17). The issues presented in Isaacson were whether the petitioner (1) failed to report taxable income for tax year 2007, and (2) if so, was the petitioner, therefore, liable for the civil fraud penalty under IRC § 6663.

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Accuracy Related Penalty

Rivera v. Commissioner (T.C. Memo. 2020-7)

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions claimed on the partnership returns, and (3) the petitioners are liable for IRC § 6662(a) accuracy-related penalties.

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Burden of Proof

Chicago Baseball Holdings, LLC v. Commissioner (T.C. Memo. 2020-2)

On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Chicago Baseball Holdings, LLC v. Commissioner (T.C. Memo. 2020-2). The issue presented in Chicago Baseball Holdings was whether prior written supervisory approval of penalties was required before the IRS communicates the penalties to the taxpayer for the first time, even if such communication was informal.

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Frost v. Commissioner (154 T.C. No. 2)

On January 7, 2020, the Tax Court issued its opinion in Frost v. Commissioner, 154 T.C. No. 2. The issue presented in Frost was whether the IRS satisfied the burden of production under IRC § 7491(c) in offering evidence of compliance with the requirement of IRC § 6751(b)(1) that the

Read More »

Grieve v. Commissioner (T.C. Memo. 2020-28)

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to the petitioner

Read More »

Isaacson v. Commissioner (T.C. Memo. 2020-17)

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Isaacson v. Commissioner (T.C. Memo. 2020-17). The issues presented in Isaacson were whether the petitioner (1) failed to report taxable income for tax year 2007, and (2) if so, was the petitioner, therefore, liable for

Read More »

Rivera v. Commissioner (T.C. Memo. 2020-7)

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions

Read More »

Chicago Baseball Holdings, LLC v. Commissioner (T.C. Memo. 2020-2)

On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Chicago Baseball Holdings, LLC v. Commissioner (T.C. Memo. 2020-2). The issue presented in Chicago Baseball Holdings was whether prior written supervisory approval of penalties was required before the IRS communicates the penalties to the taxpayer

Read More »