Penalties Under the Code
Tax Opinions

Tran v. Commissioner
T.C. Memo. 2020-27

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran v. Commissioner were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for 2006; (2) whether the petitioners failed to report gross receipts on Schedule C (Profits or Loss From Business) with regard to their nail salons in

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Scott St. Amand February 26, 2020
Penalties Under the Code
Tax Opinions

Carter v. Commissioner
T.C. Memo. 2020-21

On February 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Carter v. Commissioner (T.C. Memo. 2020-20). The issues presented in Carter v. Commissioner were whether the restrictions contained in a conservation easement violated IRC § 170(h) and whether the IRS had satisfied the prior written supervisory approval requirement of IRC § 6751(b)(1). Background to Carter v. Commissioner The petitioners, through their partnership, conveyed an easement to NALT, a “qualified organization”

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Scott St. Amand February 3, 2020
Penalties Under the Code
Tax Opinions

Isaacson v. Commissioner
T.C. Memo. 2020-17

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Isaacson v. Commissioner (T.C. Memo. 2020-17). The issues presented in Isaacson v. Commissioner were whether the petitioner (1) failed to report taxable income for tax year 2007, and (2) if so, was the petitioner, therefore, liable for the civil fraud penalty under IRC § 6663. Background to Isaacson v. Commissioner The petitioner, a trial attorney, who specialized in (among other

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Scott St. Amand January 23, 2020
Penalties Under the Code
Tax Opinions

Chadwick v. Commissioner
154 T.C. No. 5

On January 21, 2020, the Tax Court issued its opinion in Chadwick v. Commissioner (154 T.C. No. 5). The issue presented in Chadwick v. Commissioner was whether the penalty assessable pursuant to IRC § 6672(a) (the Trust Fund Recovery Penalty or TFRP) was subject to the requirement that written supervisory approval be secured at the initial determination of such assessment pursuant to IRC § 6751(b)(1). The IRC § 6672(a) Trust Fund Recovery Penalty is…Wait for

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Scott St. Amand January 21, 2020
Penalties Under the Code
Tax Opinions

Laidlaw’s Harley Davidson Sales Inc. v. Commissioner
154 T.C. No. 4

On January 16, 2020, the Tax Court issued its opinion in Laidlaw’s Harley Davidson Sales Inc. v. Commissioner (154 T.C. No. 4). The issue presented in Laidlaw’s Harley Davidson Sales Inc. v. Commissioner was whether the written supervisory approval requirement of IRC § 6751(b)(1) applied to the assessable penalty imposed by IRC § 6707A (failure to disclose a reportable transaction). 30-Day Letter Triggered IRC § 6751(b)(1) Supervisory Approval Requirement in Laidlaw’s Harley Davidson Sales Inc. v. Commissioner The

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Scott St. Amand January 16, 2020
Penalties Under the Code
Tax Opinions

Purvis v. Commissioner
T.C. Memo. 2020-13

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Purvis v. Commissioner (T.C. Memo. 2020-13). The issue presented in Purvis v. Commissioner was whether the IRS overcame their burden of proof to establish the petitioners’ liability for the taxes and the fraud penalty under IRC § 6663(a).  What a crazy case… The Quick and Dirty Background of One of the Craziest Cases I’ve Ever Read (Purvis v. Commissioner) This

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

Mei Productions v. Commissioner
T.C. Memo. 2020-11

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Mei Productions v. Commissioner (T.C. Memo. 2020-11). The issue presented in Mei Productions v. Commissioner was whether the petitioner was liable for the failure to pay under IRC § 6651(a)(3) (failure to timely pay tax assessed as an amendment to an original return). Background to Mei Productions v. Commissioner The petitioner is a California corporation, which admitted that it erroneously claimed

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Scott St. Amand January 14, 2020
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