Penalties Under the Code
Memorandum Opinions

Long Branch Land LLC v. Commissioner
T.C. Memo. 2022-2

On January 13, 2022, the Tax Court issued a Memorandum Opinion in the case of Long Branch Land LLC v. Commissioner (T.C. Memo. 2022-2). The primary issues presented in Long Branch Land LLC v. Commissioner were whether the supervisory agent possessed the authority to supervise the examination of the taxpayer and to approve the penalties imposed by revenue agent, and whether the taxpayer failed to offer clear evidence to overcome presumption of regularity of actions

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Scott St. Amand May 5, 2022
Income Tax Issues
Income Tax Issues

Elbasha v. Commissioner
T.C. Memo. 2022-1

On January 12, 2022, the Tax Court issued a Memorandum Opinion in the case of Elbasha v. Commissioner (T.C. Memo. 2022-1). The primary issues presented in Elbasha were the petitioner’s filing status and whether and to what extent the petitioner can deduct Schedule C expenses. Background to Elbasha v. Commissioner The petitioner, an emergency room doctor, was born in Sudan, and he had family there during 2008 and 2009—the years at issue. The petitioner’s Sudanese

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Scott St. Amand May 4, 2022
Procedural Issues
Memorandum Opinions

Pfetzer v. Commissioner
T.C. Memo. 2021-145

On December 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Pfetzer v. Commissioner (T.C. Memo. 2021-145). The primary issue presented in Pfetzer was whether the settlement officer failed to fulfill duty to verify that valid notices of deficiency were issued and mailed to taxpayer. Held: You betcha…but the IRS still managed to lose. Background to Pfetzer v. Commissioner The petitioner was not a model taxpayer. In point of fact, the

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Scott St. Amand May 3, 2022
Procedural Issues
Memorandum Opinions

Starcher v. Commissioner
T.C. Memo. 2021-144

On December 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Starcher v. Commissioner (T.C. Memo. 2021-144). The primary issue presented in Starcher was whether the IRS abused its discretion in upholding the filing of a notice of intent to levy. Held: Discretion sound—no abuse here. Background The petitioner did not file an income tax return for 2014, so the IRS prepared a substitute for return (SFR) for her pursuant to

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Scott St. Amand May 2, 2022
Procedural Issues
Memorandum Opinions

Whistleblower 15977-18W v. Commissioner
T.C. Memo. 2021-143

On December 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 15977-18W v. Commissioner (T.C. Memo. 2021-143). The primary issue presented in Whistleblower 15977-18W was whether the IRS’s Whistleblower Office (WBO) abused its discretion in concluding that the whistleblower claim did not provide specific and credible information sufficient to establish that the target taxpayer was citizen of United States at birth. Held: Discretion sound—no abuse here. Background In early September

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Scott St. Amand April 29, 2022
Procedural Issues
Memorandum Opinions

Ahmed v. Commissioner
T.C. Memo. 2021-142

On December 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Ahmed v. Commissioner (T.C. Memo. 2021-142). The primary issue presented in Ahmed was whether the taxpayer’s payment of all monies owed mooted his challenge to the IRS’s imposition of a lien and the trust fund recovery penalty (“TFRP”). Held: Yup. Background to Ahmed v. Commissioner In June 2020, the petitioner sent to the IRS a check for $625,000 along with

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Scott St. Amand April 28, 2022
Procedural Issues
Memorandum Opinions

Bunton v. Commissioner
T.C. Memo. 2021-141

On December 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Bunton v. Commissioner (T.C. Memo. 2021-141). The primary issue presented in Bunton was whether the IRS office of Appeals abused its discretion by sustaining a levy upon the taxpayers’ (read: tax protesters) state tax refund. Held: Not so much. Background to Bunton v. Commissioner The petitioners are tax protesters, who adopted the good ol’ “we’re not federal workers or them

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Scott St. Amand April 27, 2022
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