Penalties Under the Code
Tax Opinions

Lambert v. Commissioner
T.C. Memo. 2020-53

On May 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Lambert v. Commissioner (T.C. Memo. 2020-53). The basic issue before the court in Lambert v. Commissioner was whether the Tax Court had jurisdiction to hear the petitioner’s arguments regarding his underlying liability for tax and the trust fund recovery penalty (TFRP). Factual Background to Lambert v. Commissioner Petitioner was the vice president of a concrete business (CJB) that was incorporated

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Scott St. Amand May 6, 2020
Penalties Under the Code
Tax Opinions

Patrick’s Payroll Services Inc. v. Commissioner
T.C. Memo. 2020-47

On April 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Patrick’s Payroll Services Inc. v. Commissioner (T.C. Memo. 2020-47). The issue properly before the court in Patrick’s Payroll Services Inc. v. Commissioner was whether the petitioner is barred from challenging its underlying liabilities at trial. Background to Patrick’s Payroll Services Inc. v. Commissioner The petitioner was an employee leasing company providing payroll services in 2010 and 2011 with one client, a

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Scott St. Amand April 14, 2020
Penalties Under the Code
Tax Opinions

Shepherd v. Commissioner
T.C. Memo. 2020-45

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Shepherd v. Commissioner (T.C. Memo. 2020-45). The issue properly before the court in Shepherd v. Commissioner was whether Appeals correctly determined that the petitioner was barred from challenging his liability for the TFRPs even though he did not receive a notice of deficiency, because he had a prior opportunity to challenge his liability but failed to do so during his

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Scott St. Amand April 13, 2020
Income Tax Issues
Tax Opinions

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn v. Commissioner were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether the petitioners are entitled to theft loss deductions for their tax years 2010 and 2013; and (3) whether the petitioners are liable for

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Scott St. Amand April 9, 2020
Penalties Under the Code
Tax Opinions

McNamee v. Commissioner
T.C. Memo. 2020-37

On March 18, 2020, the Tax Court issued a Memorandum Opinion in the case of McNamee v. Commissioner (T.C. Memo. 2020-37). The issue presented in McNamee v. Commissioner was whether the petitioner was liable for 17 preparer penalties or whether the penalties had been assessed improperly for want of a final administrative determination. Background to McNamee v. Commissioner Petitioner is a CPA, who prepared income tax returns for individual taxpayers. The IRS opened an examination

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Scott St. Amand March 18, 2020
Penalties Under the Code
Tax Opinions

Bishop v. Commissioner
T.C. Memo. 2020-36

On March 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Bishop v. Commissioner (T.C. Memo. 2020-36). The issues presented in Bishop v. Commissioner were whether the petitioner could raise underlying tax liabilities before the Tax Court, and whether the IRS abused its discretion in upholding a proposed levy. Background to Bishop v. Commissioner The petitioner filed delinquent Federal income tax returns for 2013 and 2014 reporting self-employment income. For each

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Scott St. Amand March 17, 2020
Penalties Under the Code
Tax Opinions

Sun River Financial Trust v. Commissioner
T.C. Memo. 2020-30

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Sun River Financial Trust v. Commissioner (T.C. Memo. 2020-30). The single issue presented in Sun River Financial Trust v. Commissioner was whether the IRS abused its discretion in sustaining a proposed levy and the filing of a notice of Federal tax lien (NFTL) with respect to petitioner’s unpaid IRC § 6702 (frivolous return) penalties for 2010 and 2011. Background to Sun

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Scott St. Amand March 5, 2020
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