Estate Tax Issues
Estate Tax Issues

Estate of Levine v. Commissioner
158 T.C. No. 2

On February 28, 2022, the Tax Court issued the full opinion in Estate of Levine v. Commissioner (158 T.C. No. 2). The primary issues presented in Estate of Levine v. Commissioner were whether the taxpayer made a voluntary inter vivos transfer (yep); whether the taxpayer retained the right—either alone or in conjunction with her attorney-in-fact—to designate who could possess or enjoy property transferred to irrevocable life insurance trust or the income from it (thereby precluding

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Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied;

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Middleton v. Commissioner
T.C. Memo. 2022-28

On April 4, 2022, the Tax Court issued a Memorandum Opinion in the case of Middleton v. Commissioner (T.C. Memo. 2022-28). The primary issues presented in Middleton v. Commissioner were (i) whether the taxpayer could challenge the Trust Fund Recovery Penalty at his CDP hearing; and (ii) whether the taxpayer

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Villanueva v. Commissioner
T.C. Memo. 2022-27

On March 31, 2022, the Tax Court issued a Memorandum Opinion in the case of Villanueva v. Commissioner (T.C. Memo. 2022-27). The primary issue presented in Villanueva v. Commissioner was whether the petitioner was entitled to a net operating loss deduction. Held: Sorry, Edgardo, not today. Background to Villanueva v.

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Golditch v. Commissioner
T.C. Memo. 2022-26

On March 29, 2022, the Tax Court issued a Memorandum Opinion in the case of Golditch v. Commissioner (T.C. Memo. 2022-26). The primary issues presented in Golditch v. Commissioner were (i) whether the taxpayer was permitted to challenge his underlying tax liability at CDP hearing; (ii) whether the taxpayer’s argument

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Porter v. Commissioner
T.C. Memo. 2022-25

On March 28, 2022, the Tax Court issued a Memorandum Opinion in the case of Porter v. Commissioner (T.C. Memo. 2022-25). The primary issues presented in Porter v. Commissioner were whether (i) delays in examination and litigation were attributable to IRS officer or could significantly be attributed to taxpayer; and

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Addis v. Commissioner
T.C. Memo. 2022-24

On March 28, 2022, the Tax Court issued a Memorandum Opinion in the case of Addis v. Commissioner (T.C. Memo. 2022-24). The primary issue presented in Addis v. Commissioner was whether the frivolous taxpayer’s CDP rights had been violated. Held: Not quite, Jonah. Mr. Addis’s 2014 Tax Reporting On March

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