Income Tax Issues
Income Tax Issues

Amburgey v. Commissioner (T.C. Memo. 2021-124)

On November 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Amburgey v. Commissioner (T.C. Memo. 2021-124). The primary issue presented in Amburgey was whether the petitioners were required to repay an advance premium tax credit, or whether requiring them to do so was unconstitutional. Held: Pay up, petitioners. Background The petitioners, a married couple, reported an adjusted gross income of $181,183 on their joint Federal income tax return for 2018.

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Memorandum Opinions

Cashaw v. Commissioner (T.C. Memo. 2021-123)

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Cashaw v. Commissioner (T.C. Memo. 2021-123). The primary issue presented in Cashaw was whether the petitioner is liable for trust fund recovery penalties. Held: Yup. Background to Cashaw v. Commissioner The petitioner was presented with difficult choices during her tenure as temporary chief administrator of a hospital. The hospital was under a state order freezing its bank accounts except for

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Procedural Issues
Memorandum Opinions

Hill v. Commissioner (T.C. Memo. 2021-121)

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Hill v. Commissioner (T.C. Memo. 2021-121). The primary issue presented in Hill was whether the petitioner’s remittance of $10.3 million to the IRS to be applied toward an anticipated gift tax liability for 2011, which remittance was designated as a “deposit” was a “deposit” or a “payment” for purposes of determining whether interest was due to the petitioner. Held: Look,

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Memorandum Opinions

Morris v. Commissioner (T.C. Memo. 2021-120)

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Morris v. Commissioner (T.C. Memo. 2021-120). The primary issue presented in Morris was whether the petitioner’s or liable for penalties for failure to timely file (IRC § 6651(a)(1)), failure to timely pay (IRC § 6651(a)(2)), and failure to pay estimated tax (IRC § 6654). Held: Yes. Yes, they were. Background to Morris v. Commissioner Mr. Morris was a successful businessman,

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Business Related Issues

Tribune Media Company v. Commissioner (T.C. Memo. 2021-122)

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Tribune Media Company v. Commissioner (T.C. Memo. 2021-122). The primary issue presented in Tribune Media Company was whether the Ricketts family (a partner of the petitioner in “Chicago Baseball Holdings, LLC”) entered into a “bona fide debt” for tax purposes. (You may remember these parties from the January 2020 decision of Chicago Baseball Holdings v. Commissioner, T.C. Memo. 2020-2). Held:

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Business Related Issues

Goldberg v. Commissioner (T.C. Memo. 2021-119)

On October 19, 2021, the Tax Court issued a Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2021-119). The primary issue presented in Goldberg was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC § 6320 or because of his nonparticipation in an even earlier TEFRA proceedings

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Income Tax Issues
Income Tax Issues

Dodd v. Commissioner (T.C. Memo. 2021-118)

On October 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Dodd v. Commissioner (T.C. Memo. 2021-118). The primary issue presented in Dodd were whether the petitioner was liable for the unpaid tax related to unreported IRC § 1231 gain Holding: Indeed she was. Background During 2013, the petitioner in Dodd v. Commissioner was employed as the office manager of a law firm in Washington, D.C. During 2013, and continuing at

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Partial Payments of Tax and Deposits with the IRS

Sunday afternoon rolls around, and the last thing on your mind was explaining the pros and cons of making partial payments of tax and deposits with the IRS to a relative who still sees “Charlie” lurking in his backyard from time to time. Nonetheless, of all of your relatives, Cousin

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Amburgey v. Commissioner (T.C. Memo. 2021-124)

On November 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Amburgey v. Commissioner (T.C. Memo. 2021-124). The primary issue presented in Amburgey was whether the petitioners were required to repay an advance premium tax credit, or whether requiring them to do so was unconstitutional. Held:

Read More »

Cashaw v. Commissioner (T.C. Memo. 2021-123)

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Cashaw v. Commissioner (T.C. Memo. 2021-123). The primary issue presented in Cashaw was whether the petitioner is liable for trust fund recovery penalties. Held: Yup. Background to Cashaw v. Commissioner The petitioner was presented with

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Statutes of Limitation on Assessment and Collection

One of the most common questions I am asked by taxpayers is “How long can the IRS try to collect my liability?” It’s a good question, and one that would seem to have a quick, easy answer. Judging purely by the length of this article, however, the answer is never

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Hill v. Commissioner (T.C. Memo. 2021-121)

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Hill v. Commissioner (T.C. Memo. 2021-121). The primary issue presented in Hill was whether the petitioner’s remittance of $10.3 million to the IRS to be applied toward an anticipated gift tax liability for 2011, which

Read More »