Procedural Issues
Full Tax Court Opinions

Ramey v. Commissioner
156 T.C. No. 1

On January 14, 2021, the Tax Court issued its opinion in Ramey v. Commissioner (156 T.C. No. 1). The underlying issue presented in Ramey v. Commissioner was whether notice sent to last known address, shared by multiple businesses, and not left with anyone authorized to receive the petitioner’s mail, started the CDP Appeal clock in IRC § 6330(a)(2) and (3). Legal Background to Ramey v. Commissioner The IRS may not make a levy unless the

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Scott St. Amand January 14, 2021
Procedural Issues
Tax Opinions

Boettcher v. Commissioner
T.C. Memo. 2021-4

On January 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Boettcher v. Commissioner (T.C. Memo. 2021-3). The issue presented in Boettcher v. Commissioner was whether the settlement officer failed to properly consider the installment agreement requested by the petitioners. Background to Boettcher v. Commissioner Petitioner-husband was a news-correspondent-turned-college-professor and petitioner-wife was an attorney (likely not a tax attorney, as you’ll see).  The petitioners delinquently filed their tax returns, but, apparently,

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Scott St. Amand January 12, 2021
Procedural Issues
Tax Opinions

Kennedy v. Commissioner (T.C. Memo. 2021-3)

On January 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Kennedy v. Commissioner (T.C. Memo. 2021-3). The issue presented in Kelley was whether the IRS’s whistleblower office abused its discretion in denying the petitioner’s claims. Background The petitioner claimed that three subsidiaries of a taxpayer owed a middling $150m in unpaid excise taxes, penalties, and interest to Uncle Sam.  The IRS Whistleblower Office (WBO) reviewed the claim, and to everyone’s

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Scott St. Amand January 12, 2021
Procedural Issues
Tax Opinions

Dang v. Commissioner
T.C. Memo. 2020-150

On November 9, 2020, the Tax Court issued a Memorandum Opinion in the case Dang v. Commissioner (T.C. Memo. 2020-150). The primary issue before the court in Dang v. Commissioner was whether the petitioners incurred “reasonable administrative costs” under IRC § 7430 and whether the petitioners are entitled to an award of reasonable litigation costs.

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Scott St. Amand November 9, 2020
Procedural Issues
Tax Opinions

Oropeza v. Commissioner
155 T.C. No. 9

On October 13, 2020, the Tax Court issued its opinion in Oropeza v. Commissioner (155 T.C. No. 9). The primary issue presented in Oropeza v. Commissioner was whether the IRS obtained prior supervisory approval pursuant to IRC § 6751(b)(1) prior to its initial determination to assess a penalty against the petitioner for tax year 2011.  Specifically, the issue in Oropeza v. Commissioner was whether a Letter 5153 accompanied by a Form 4549-A (an RAR) constituted

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Scott St. Amand October 13, 2020
Procedural Issues
Tax Opinions

Worthington v. Commissioner
T.C. Memo. 2020-141

On October 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Worthington v. Commissioner (T.C. Memo. 2020-141). The issue before the court in Worthington v. Commissioner was whether the IRS’s whistleblower office abused its discretion in denying or rejecting the petitioner’s claim. Not a Propitious Beginning to Worthington v. Commissioner In mid-November 2018, the petitioner filed a claim against John Worthington.  The trouble was, the petitioner was John Worthington.  Just like

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Scott St. Amand October 8, 2020
Procedural Issues
Tax Opinions

Spagnoletti v. Commissioner
T.C. Memo. 2020-140

On October 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Spagnoletti v. Commissioner (T.C. Memo. 2020-140). The issue before the court in Spagnoletti v. Commissioner was whether the IRS abused its discretion in sustaining the proposed levy when it denied the petitioner’s request, who requested to full pay his liability in four payments but failed to submit financial documentation. Background to Spagnoletti v. Commissioner The petitioner (an attorney) filed delinquent

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Scott St. Amand October 8, 2020
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