Procedural Issues
Memorandum Opinions

Benson v. Commissioner
T.C. Memo. 2021-78

On June 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Benson v. Commissioner (T.C. Memo. 2021-78). The primary issue presented in Benson v. Commissioner was whether the petitioner was precluded from challenging his underlying liabilities in a CDP case. Background to Benson v. Commissioner The petitioner has sought to challenge his 2008 and 2009 tax liabilities both in his CDP hearing and in this Court. The petitioner had two prior

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Scott St. Amand July 12, 2021
Penalties Under the Code
Memorandum Opinions

Muhammad v. Commissioner
T.C. Memo. 2021-77

On June 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Muhammad v. Commissioner (T.C. Memo. 2021-77). The primary issue presented in Muhammad v. Commissioner was whether the petitioner’s arguments were completely frivolous, or just a little frivolous, so as to support the frivolous argument penalty under IRC § 6673(a)(1)(B). Held: Petitioner was completely full of shit; penalties ensued. Overview of Muhammad v. Commissioner The question presented in this case is

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Scott St. Amand July 12, 2021
Procedural Issues
Memorandum Opinions

Kelly v. Commissioner
T.C. Memo. 2021-76

On June 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelly v. Commissioner (T.C. Memo. 2021-76). The primary issues presented in Kelly v. Commissioner were whether transfers from a company to the petitioner were loans, and if so, whether the petitioner received taxable distributions or cancellation of indebtedness (COD) income when the loans were cancelled. Background to Kelly v. Commissioner The petitioner was a 50% owner of Lucky Bastard Records.

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Scott St. Amand July 12, 2021
Penalties Under the Code
Memorandum Opinions

Ervin v. Commissioner
T.C. Memo. 2021-75

On June 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Ervin v. Commissioner (T.C. Memo. 2021-75). The primary issue presented in Ervin v. Commissioner was whether the petitioner’s criminal restitution payments satisfied his income tax liability. Background to Ervin v. Commissioner This may be a rather vast generalization, but most folks named Monty are not the most trustworthy.  Monty Ervin is one such Monty.  Monty failed to file Federal income

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Scott St. Amand July 12, 2021
Penalties Under the Code
Memorandum Opinions

Bell Capital Management Inc. v. Commissioner
T.C. Memo. 2021-74

Bell Capital Management, Inc. v. Commissioner (T.C. Memo. 2021-74) On June 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Bell Capital Management, Inc.v. Commissioner (T.C. Memo. 2021-74). The primary issues presented in Bell Capital Management, Inc. were whether (1) petitioner is collaterally estopped from denying that it was responsible for paying the employment taxes; (2) whether the IRS properly determined that Ron H. Bell should be legally classified as petitioner’s

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Scott St. Amand June 21, 2021
Procedural Issues
Memorandum Opinions

Whistleblower 1008416W v. Commissioner
T.C. Memo. 2021-73

On June 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 1008416W v. Commissioner (T.C. Memo. 2021-73). The primary issue presented in Whistleblower 1008416W v. Commissioner was whether the IRS abused its discretion in denying petitioner’s claim for a whistleblower award. Background to Whistleblower 1008416W v. Commissioner In June 2010, the petitioner provided whistleblower information about the target taxpayer (target) to an attorney with respondent’s Office of Chief Counsel and delivered

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Scott St. Amand June 21, 2021
International Issues
International Issues

Landrau v. Commissioner
T.C. Memo. 2021-72

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Landrau v. Commissioner (T.C. Memo. 2021-72). The primary issue presented in Landrau was whether the IRS correctly computed their allowable foreign tax credit for 2012. Background to Landrau v. Commissioner During 2014 petitioner-husband received wages of $74,680 for services performed in Puerto Rico for the U.S. Air Force. Petitioner-wife received a pension distribution of $10,380 and U.S. Social Security benefits of

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Scott St. Amand June 21, 2021
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