Frivolous

Delgado v. Commissioner (T.C. Memo. 2021-84)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Delgado v. Commissioner (T.C. Memo. 2021-84). The primary issue presented in Delgado was whether the petitioner’s frivolous argument that he did not receive taxable income in 2017 because he was not engaged in a “trade or business” as defined by IRC § 7701(a)(26) held any water… Quick Work of the Frivolousness Compensation for services is included in gross income. IRC

Read More »
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

Read More »
Crazy Germans

Schwager v. Commissioner (T.C. Memo. 2020-83)

On June 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Schwager v. Commissioner (T.C. Memo. 2020-83). The issue before the court in Schwager was whether the IRS abused its discretion in dismissing as frivolous the petitioner’s arguments made during the CPD hearing and sustaining the proposed levy action.

Read More »
Appeals Division

Etoty v. Commissioner (T.C. Memo. 2020-49)

On April 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Etoty v. Commissioner (T.C. Memo. 2020-49). The issue before the court in Etoty was whether the levy on the petitioner’s New York State tax refund should not [sic] be sustained.

Read More »
Assessable Penalties

Sun River Financial Trust v. Commissioner (T.C. Memo. 2020-30)

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Sun River Financial Trust v. Commissioner (T.C. Memo. 2020-30). The single issue presented in Sun River Financial Trust was whether the IRS abused its discretion in sustaining a proposed levy and the filing of a notice of Federal tax lien (NFTL) with respect to petitioner’s unpaid IRC § 6702 (frivolous return) penalties for 2010 and 2011.

Read More »
Abuse of Discretion

Pulcine v. Commissioner (T.C. Memo. 2020-29)

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Pulcine v. Commissioner (T.C. Memo. 2020-29). The primary issue presented in Pulcine was whether a whistleblower, whose report initiated an audit of the alleged bad actor, which ultimately resulted in the “bad actor” receiving a refund on his return, demonstrated that the IRS’s Whistleblower Office (WBO) abused its discretion in not awarding the whistleblower for his information.

Read More »
Abuse of Discretion

Alber v. Commissioner (T.C. Memo. 2020-20)

On January 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Alber v. Commissioner (T.C. Memo. 2020-20). The issue presented in Alber was whether the Whistleblower Office of the IRS abused its discretion in summarily rejecting a whistleblower’s claim on the basis that the information provided to support such claim was speculative and/or did not provide specific or credible information regarding tax underpayments or violations of internal revenue laws.

Read More »
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Delgado v. Commissioner (T.C. Memo. 2021-84)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Delgado v. Commissioner (T.C. Memo. 2021-84). The primary issue presented in Delgado was whether the petitioner’s frivolous argument that he did not receive taxable income in 2017 because he was not engaged in a “trade

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 »

Schwager v. Commissioner (T.C. Memo. 2020-83)

On June 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Schwager v. Commissioner (T.C. Memo. 2020-83). The issue before the court in Schwager was whether the IRS abused its discretion in dismissing as frivolous the petitioner’s arguments made during the CPD hearing and sustaining the

Read More »

Etoty v. Commissioner (T.C. Memo. 2020-49)

On April 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Etoty v. Commissioner (T.C. Memo. 2020-49). The issue before the court in Etoty was whether the levy on the petitioner’s New York State tax refund should not [sic] be sustained.

Read More »

Sun River Financial Trust v. Commissioner (T.C. Memo. 2020-30)

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Sun River Financial Trust v. Commissioner (T.C. Memo. 2020-30). The single issue presented in Sun River Financial Trust was whether the IRS abused its discretion in sustaining a proposed levy and the filing of a

Read More »

Pulcine v. Commissioner (T.C. Memo. 2020-29)

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Pulcine v. Commissioner (T.C. Memo. 2020-29). The primary issue presented in Pulcine was whether a whistleblower, whose report initiated an audit of the alleged bad actor, which ultimately resulted in the “bad actor” receiving a

Read More »

Alber v. Commissioner (T.C. Memo. 2020-20)

On January 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Alber v. Commissioner (T.C. Memo. 2020-20). The issue presented in Alber was whether the Whistleblower Office of the IRS abused its discretion in summarily rejecting a whistleblower’s claim on the basis that the information provided

Read More »