Penalties Under the Code
CDP

Lambert v. Commissioner
T.C. Memo. 2020-53

On May 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Lambert v. Commissioner (T.C. Memo. 2020-53). The basic issue before the court in Lambert v. Commissioner was whether the Tax Court had jurisdiction to hear the petitioner’s arguments regarding his underlying liability for tax and the trust fund recovery penalty (TFRP). Factual Background to Lambert v. Commissioner Petitioner was the vice president of a concrete business (CJB) that was incorporated

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Scott St. Amand May 6, 2020
Penalties Under the Code
CDP

Shepherd v. Commissioner
T.C. Memo. 2020-45

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Shepherd v. Commissioner (T.C. Memo. 2020-45). The issue properly before the court in Shepherd v. Commissioner was whether Appeals correctly determined that the petitioner was barred from challenging his liability for the TFRPs even though he did not receive a notice of deficiency, because he had a prior opportunity to challenge his liability but failed to do so during his

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Scott St. Amand April 13, 2020
Penalties Under the Code
"Penalty" Means "Penalty"

Chadwick v. Commissioner
154 T.C. No. 5

On January 21, 2020, the Tax Court issued its opinion in Chadwick v. Commissioner (154 T.C. No. 5). The issue presented in Chadwick v. Commissioner was whether the penalty assessable pursuant to IRC § 6672(a) (the Trust Fund Recovery Penalty or TFRP) was subject to the requirement that written supervisory approval be secured at the initial determination of such assessment pursuant to IRC § 6751(b)(1). The IRC § 6672(a) Trust Fund Recovery Penalty is…Wait for

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Scott St. Amand January 21, 2020
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Lambert v. Commissioner
T.C. Memo. 2020-53

On May 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Lambert v. Commissioner (T.C. Memo. 2020-53). The basic issue before the court in Lambert v. Commissioner was whether the Tax Court had jurisdiction to hear the petitioner’s arguments regarding his underlying liability for tax and

Read More »
Scott St. Amand May 6, 2020

Shepherd v. Commissioner
T.C. Memo. 2020-45

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Shepherd v. Commissioner (T.C. Memo. 2020-45). The issue properly before the court in Shepherd v. Commissioner was whether Appeals correctly determined that the petitioner was barred from challenging his liability for the TFRPs even though

Read More »
Scott St. Amand April 13, 2020

Chadwick v. Commissioner
154 T.C. No. 5

On January 21, 2020, the Tax Court issued its opinion in Chadwick v. Commissioner (154 T.C. No. 5). The issue presented in Chadwick v. Commissioner was whether the penalty assessable pursuant to IRC § 6672(a) (the Trust Fund Recovery Penalty or TFRP) was subject to the requirement that written supervisory

Read More »
Scott St. Amand January 21, 2020