Business Related Issues
Tax Opinions

Elkins v. Commissioner
T.C. Memo. 2020-110

On July 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Elkins v. Commissioner (T.C. Memo. 2020-110). The primary issue before the court in Elkins v. Commissioner was whether Appeals abused its discretion when it sustained the rejection of the petitioner’s offer-in-compromise (OIC) on the ground that it was not in the best interest of the Government. Computational Adjustments to Partner’s Liabilities After Conclusion of Partnership-Level Proceeding in Elkins v. Commissioner

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Scott St. Amand July 16, 2020
Procedural Issues
Tax Opinions

Dodson v. Commissioner
T.C. Memo. 2020-106

On July 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Dodson v. Commissioner (T.C. Memo. 2020-106). The primary issue before the court in Dodson v. Commissioner was whether the IRS abused its discretion by denying the petitioners’ proposed installment agreement. Petitioners in Dodson v. Commissioner Not Paragons of Tax Compliance The petitioners are in the real estate business, earning income from real estate brokerage and from rental of properties that

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

Dennis v. Commissioner
T.C. Memo. 2020-98

On July 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Dennis v. Commissioner (T.C. Memo. 2020-98). The primary issue before the court in Dennis v. Commissioner was whether the petitioners were entitled to reasonable litigation or administrative costs when, after CDP appeals, petition, and remand from Tax Court to Appeals, the IRS conceded all issues. Brief Background in Dennis v. Commissioner The IRS screwed this one up, but they were

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Scott St. Amand July 1, 2020
Procedural Issues
Tax Opinions

Nguyen v. Commissioner
T.C. Memo. 2020-96

On June 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Nguyen v. Commissioner (T.C. Memo. 2020-96). The basic, threshold issue before the court in Nguyen v. Commissioner was whether the petitioner may challenge his underlying liability in the Tax Court. Brief Background to Nguyen v. Commissioner the IRS sent, by certified mail, a notice of deficiency for the years in issue to the petitioner at his last-known address. The notice

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Scott St. Amand June 30, 2020
Procedural Issues
Tax Opinions

Ruesch v. Commissioner (154 T.C. No. 13)

On June 25, 2020, the Tax Court issued its opinion in Ruesch v. Commissioner (154 T.C. No. 13). The two issues in Ruesch v. Commissioner were (1) whether the Tax Court possessed jurisdiction under IRC § 7345(b) to consider the petitioner’s challenge to her underlying tax debts; and (2) whether the Tax Court possessed jurisdiction to review the petitioner’s challenge to the IRS’s certification of the petitioner’s liabilities as “seriously delinquent pursuant to IRC §

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Scott St. Amand June 25, 2020
Procedural Issues
Tax Opinions

Cosio v. Commissioner
T.C. Memo. 2020-90

On June 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Cosio v. Commissioner (T.C. Memo. 2020-90). The primary issue before the court in Cosio v. Commissioner was whether the petitioner received a reasonable opportunity to present evidence pertaining to his tax liability for 2015, when all notices sent to the petitioner referenced his 2012 liability and his right to a hearing thereupon. Background to Cosio v. Commissioner From the limited

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Scott St. Amand June 18, 2020
Procedural Issues
Tax Opinions

Abeuova v. Commissioner
T.C. Memo. 2020-86

On June 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Abeuova v. Commissioner (T.C. Memo. 2020-86). The issue before the court in Abeuova v. Commissioner was whether the IRS sent the notice of deficiency to the petitioners last known address, and if so, whether the Tax Court has jurisdiction because of the untimely filing of the petition. The Erroneous Zip Code Addendum in Abeuova v. Commissioner Petitioners’ five-digit ZIP Code

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Scott St. Amand June 16, 2020
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