Procedural Issues
Admissions by Taxpayer

Joseph v. Commissioner
T.C. Memo. 2020-65

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Joseph v. Commissioner (T.C. Memo. 2020-65). The issue before the court in Joseph v. Commissioner was whether a petitioners’ concessions in a stipulation of settled issues regarding capital gain and income could subsequently be used by the IRS to amend the IRS’s answer to a Tax Court petition, and if so, whether the stipulation should be modified or set aside

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Scott St. Amand May 19, 2020
Procedural Issues
Jurisdiction of Tax Court

Lord Pope v. Commissioner
T.C. Memo. 2020-62

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Pope v. Commissioner (T.C. Memo. 2020-62). The basic issue before the court in Pope was whether the Tax Court lacks jurisdiction to redetermine a deficiency under IRC § 6213(a) when no deficiency was determined but which determination reduces the petitioners’ claimed entitlement to a refund. Background to Pope v. Commissioner Nothing against Judge Lauber – I genuinely appreciate his no

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Scott St. Amand May 18, 2020
Procedural Issues
Abuse of Discretion

Northside Carting Inc. v. Commissioner
T.C. Memo. 2020-18

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Northside Carting Inc. v. Commissioner (T.C. Memo. 2020-18). The primary issue presented in Northside Carting Inc. v. Commissioner was whether the IRS abused its discretion by rejecting collection alternatives (an installment agreement) raised in an equivalent hearing. Background to Northside Carting Inc. v. Commissioner The petitioner’s business is garbage and has been garbage since 1996. At the time the petition was

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Scott St. Amand January 23, 2020
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Joseph v. Commissioner
T.C. Memo. 2020-65

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Joseph v. Commissioner (T.C. Memo. 2020-65). The issue before the court in Joseph v. Commissioner was whether a petitioners’ concessions in a stipulation of settled issues regarding capital gain and income could subsequently be used

Read More »
Scott St. Amand May 19, 2020

Lord Pope v. Commissioner
T.C. Memo. 2020-62

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Pope v. Commissioner (T.C. Memo. 2020-62). The basic issue before the court in Pope was whether the Tax Court lacks jurisdiction to redetermine a deficiency under IRC § 6213(a) when no deficiency was determined but

Read More »
Scott St. Amand May 18, 2020

Northside Carting Inc. v. Commissioner
T.C. Memo. 2020-18

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Northside Carting Inc. v. Commissioner (T.C. Memo. 2020-18). The primary issue presented in Northside Carting Inc. v. Commissioner was whether the IRS abused its discretion by rejecting collection alternatives (an installment agreement) raised in an equivalent

Read More »
Scott St. Amand January 23, 2020