Procedural Issues
Memorandum Opinions

Brown v. Commissioner
T.C. Memo. 2021-112

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Brown v. Commissioner (T.C. Memo. 2021-112). The sole issue presented in Brown v. Commissioner was whether the Tax Court has jurisdiction to order the refund of a TIPRA payment. What is a TIPRA Payment? The Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA), Pub. L. No. 109-222, § 509(a), enacted new IRC § 7122(c), effective for offers-in-compromise (OICs) submitted on

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Scott St. Amand October 11, 2021
Income Tax Issues
Income Tax Issues

Parker v. Commissioner
T.C. Memo. 2021-111

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Parker v. Commissioner (T.C. Memo. 2021-111). The primary issues presented in Parker v. Commissioner were (1) whether petitioners can deduct, on Schedule C (Profit or Loss From Business), car and truck expenses in excess of the amount the IRS allowed; (2) whether petitioners can deduct retirement contributions in excess of the amount the IRS allowed; (3) whether petitioners can deduct expenses

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Scott St. Amand October 10, 2021
Income Tax Issues
Income Tax Issues

Sutherland v. Commissioner
T.C. Memo. 2021-110

On September 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Sutherland v. Commissioner (T.C. Memo. 2021-110). The primary issue presented in Sutherland v. Commissioner was whether the petitioner was eligible for relief from joint and several liability under IRC § 6015(f). Background to Sutherland v. Commissioner Donna Sutherland Scott Sutherland operated Sutherland Installation and Services (SIS), a business that installed and maintained draft beer systems at restaurants, sports complexes, and other

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Scott St. Amand October 9, 2021
International Issues
International Issues

Kaebel v. Commissioner
T.C. Memo. 2021-109

On September 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Kaebel v. Commissioner (T.C. Memo. 2021-109). The primary issues presented in Kaebel v. Commissioner were (a) whether the petitioner was precluded from arguing that the IRS did not send him deficiency notices; (b) whether the IRS erred in certifying that the petitioner had seriously delinquent tax debt; and (c) whether the petitioner should be sanctioned for advancing the groundless argument that

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Scott St. Amand October 8, 2021
Procedural Issues
Memorandum Opinions

Pazden v. Commissioner
T.C. Memo. 2021-108

On September 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Pazden v. Commissioner (T.C. Memo. 2021-108). The primary issues presented in Pazden were (1) whether Ms. Pazden is entitled to challenge her underlying tax liability for 2010, and (2) whether Appeals abused its discretion in sustaining the proposed levy in this case. Held: Nope and Nope. Background Ms. Pazden failed to timely file her 2010 Federal income tax return. The

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Scott St. Amand October 7, 2021
Income Tax Issues
Income Tax Issues

Gaston v. Commissioner
T.C. Memo. 2021-107

On September 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Gaston v. Commissioner (T.C. Memo. 2021-107). The primary issue presented in Gaston v. Commissioner was whether the petitioner engaged in acting as a trade or business in the tax years at issue and, if so, whether the petitioner is entitled to deduct any reported expenses relating to that trade or business. Background to Gaston v. Commissioner: A Pink Cadillac The petitioner

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Scott St. Amand October 6, 2021
Procedural Issues
Memorandum Opinions

Chow v. Commissioner
T.C. Memo. 2021-106

On September 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Chow v. Commissioner (T.C. Memo. 2021-106). The primary issue presented in Chow v. Commissioner was whether the IRS’s Whistleblower Office (WBO) abused its discretion when it denied the petitioners’ claim on the basis that the information that they provided was bullshit (rather, “not credible”). Held: No. You people are crazy. Background to Chow v. Commissioner Mr. and Mrs. Wai-Cheung Wilson Chow

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Scott St. Amand October 5, 2021
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