Income Tax Issues
Full Tax Court Opinions

Coggin v. Commissioner
157 T.C. No. 12

On December 8, 2021, the Tax Court issued its opinion in Coggin v. Commissioner, 157 T.C. No. 12. The primary issue presented in Coggin was whether the Tax Court lacked jurisdiction in a refund suit for years in which the District Court had previously acquired jurisdiction. Background The petitioner filed amended returns for tax years 2001 through 2009, claiming refunds for 2001 through 2007. The IRS rejected the refund requests for 2003, 2004, and 2007.

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Penalties Under the Code
Full Tax Court Opinions

Sand Investment Co. v. Commissioner
157 T.C. No. 11

On November 23, 2021, the Tax Court issued its opinion in Sand Investment Co. v. Commissioner, 157 T.C. No. 11. The primary issue presented in Sand Investment Co. was whether the IRS obtained prior written supervisory approval pursuant to IRC § 6751(b)(1) insofar as whether the individual who made the initial determination received approval from its immediate supervisor. Held: Yeah…no dice, petitioner. Dueling Determinations The RA’s case and issue manager, Mr. Burris, signed the form

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Procedural Issues
Full Tax Court Opinions

Ruhaak v. Commissioner
157 T.C. No. 9

On November 16, 2021, the Tax Court issued its opinion in Ruhaak v. Commissioner, 157 T.C. No. 9. The primary issue presented in Ruhaak was whether the petitioner’s request for a hearing made before the expiration of the 30-day period following the mailing date of the levy notice necessarily triggered a CDP hearing and not an equivalent hearing. Held: Timing is everything. Background to Ruhaak v. Commissioner The IRS sent the petitioner a Notice of

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Procedural Issues
Full Tax Court Opinions

Insinga v. Commissioner
157 T.C. No. 8

On October 27, 2021, the Tax Court issued its opinion in Insinga v. Commissioner (157 T.C. No. 8). The primary issue presented in Insinga v. Commissioner was whether the Tax Court’s jurisdiction over a whistleblower petition filed under IRC § 7623(b)(4) was extinguished by the death of the petitioner-whistleblower. Held: Heck no; whistle on whistler. Background to Insinga v. Commissioner Pursuant to IRC § 7623(b)(4), the petitioner filed a timely petition in the Tax Court

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Income Tax Issues
Full Tax Court Opinions

Leyh v. Commissioner
157 T.C. No. 7

On October 4, 2021, the Tax Court issued its opinion in Leyh v. Commissioner (157 T.C. No. 7). The primary issue presented in Leyh v. Commissioner was whether the petitioner was entitled to deduct, as alimony, an amount equal to the premiums paid to provide health insurance coverage for his then spouse Held:  Yes, sir. Background to Leyh v. Commissioner In 2012, the petitioner in Leyh v. Commissioner, Mr. Leyh, filed for divorce from his then wife,

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Procedural Issues
Full Tax Court Opinions

Rogers v. Commissioner
157 T.C. No. 3

On August 2, 2021, the Tax Court issued its opinion in Rogers v. Commissioner (157 T.C. No. 3). The primary issue presented in Rogers v. Commissioner was whether the IRS Whistleblower Office abused its discretion when it rejected/denied the petitioner’s claim. Held: Oh yeah. Side Note One of the attorneys for the IRS is named Bartholomew Cirenza. There’s a fair to middling chance that he has been given more swirlies, wedgies, and other sundry childhood punishments

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Hamilton v. Commissioner
T.C. Memo. 2022-21

On March 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Hamilton v. Commissioner (T.C. Memo. 2022-21). The primary issues presented in Hamilton v. Commissioner were (1) whether the Tax Court would consider taxpayers’ testimony and documentary evidence; (2) whether the notices of determination contained plain

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Bunton v. Commissioner
T.C. Memo. 2022-20

On March 10, 2022, the Tax Court issued a Memorandum Opinion in the case of Bunton v. Commissioner (T.C. Memo. 2022-20). The primary issues presented in Bunton v. Commissioner were (1) whether Brian and Karen were entitled to challenge the existence and amounts of their underlying tax liabilities for the

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DelPonte v. Commissioner
158 T.C. No. 7

On May 5, 2022, the Tax Court issued the full opinion in DelPonte v. Commissioner (158 T.C. No. 7). The primary issue presented in DelPonte v. Commissioner was whether the IRS’s Cincinnati Centralized Innocent Spouse Operation (CCISO) or the IRS’s Office of Chief Counsel has the final authority to determine

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Treece Financial Services Group v. Commissioner
158 T.C. No. 6

On April 19, 2022, the Tax Court issued the full opinion in Treece Financial Services Group v. Commissioner (158 T.C. No. 6). The primary issue presented in Treece Financial Services Group v. Commissioner was whether the Tax Court had jurisdiction to determine whether Voluntary Classification Settlement Program (VCSP) entered into

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BATS Global Markets Holdings Inc. v. Commissioner
158 T.C. No. 5

On March 31, 2022, the Tax Court issued the full opinion in BATS Global Markets Holdings Inc. v. Commissioner (158 T.C. No. 5). The primary issue presented in BATS Global Markets Holdings Inc. v. Commissioner was whether the petitioner’s transaction fees, routing fees, and logical port fees qualify as domestic

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Aptargroup Inc. v. Commissioner
158 T.C. No. 4

On March 16, 2022, the Tax Court issued the full opinion in Aptargroup Inc. v. Commissioner (158 T.C. No. 4). The primary issue presented in Aptargroup Inc. v. Commissioner was whether the taxpayer was required to characterize stock in controlled foreign corporation using gross income method. Held: Yes, indeed it

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