Procedural Issues
Tax Opinions

Nimmo v. Commissioner
T.C. Memo. 2020-72

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Nimmo v. Commissioner (T.C. Memo. 2020-72). The sole issue before the court in Nimmo v. Commissioner was whether the IRS abused its discretion in sustaining the collection action against petitioner, who failed to attend (call into) his initial CDP hearing, failed to submit required documentation at his subsequent CDP hearing (on another tax period), and otherwise failed to communicate with

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

Larkin v. Commissioner (T.C. Memo. 2020-70)

On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Larkin v. Commissioner (T.C. Memo. 2020-70). The underlying issue before the court in Larkin v. Commissioner was whether the petitioners provided substantial, credible evidence to support their deductions claimed on their returns for the years at issue. Although there are a number of sub-issues, the entry of arguments and evidence into the record through pleading and briefs is the primary

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Scott St. Amand May 28, 2020
Procedural Issues
Tax Opinions

Amanda Iris Gluck Irrevocable Trust v. Commissioner
154 T.C. No. 11

On May 26, 2020, the Tax Court issued its opinion in Amanda Iris Gluck Irrevocable Trust v. Commissioner (154 T.C. No. 11). The main issue in Amanda Iris Gluck Irrevocable Trust v. Commissioner was whether the Tax Court could consider a challenge to the petitioner’s underlying tax liabilities which were computed by “computational adjustment.” A secondary issue was whether the Tax Court possessed the jurisdiction to hear a challenge for a year not subject to

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Scott St. Amand May 26, 2020
Procedural Issues
Tax Opinions

Joseph v. Commissioner
T.C. Memo. 2020-65

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Joseph v. Commissioner (T.C. Memo. 2020-65). The issue before the court in Joseph v. Commissioner was whether a petitioners’ concessions in a stipulation of settled issues regarding capital gain and income could subsequently be used by the IRS to amend the IRS’s answer to a Tax Court petition, and if so, whether the stipulation should be modified or set aside

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Scott St. Amand May 19, 2020
Procedural Issues
Tax Opinions

Frantz v. Commissioner
T.C. Memo. 2020-64

On May 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Frantz v. Commissioner (T.C. Memo. 2020-64). The issue before the court in Frantz v. Commissioner was whether the IRS Whistleblower Office abused its discretion to investigate a claim against the trustee of the petitioner’s chapter 7 bankruptcy estate, who the petitioner claimed significantly understated the estate’s tax liability. Background to Frantz v. Commissioner The petitioner was a potato farmer, or

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Scott St. Amand May 19, 2020
Procedural Issues
Tax Opinions

Lord Pope v. Commissioner
T.C. Memo. 2020-62

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Pope v. Commissioner (T.C. Memo. 2020-62). The basic issue before the court in Pope was whether the Tax Court lacks jurisdiction to redetermine a deficiency under IRC § 6213(a) when no deficiency was determined but which determination reduces the petitioners’ claimed entitlement to a refund. Background to Pope v. Commissioner Nothing against Judge Lauber – I genuinely appreciate his no

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

Nesbitt v. Commissioner
T.C. Memo. 2020-61

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Nesbitt v. Commissioner (T.C. Memo. 2020-61). The basic issue before the court in Nesbitt v. Commissioner was whether the IRS abused its discretion in sustaining a proposed levy and rejecting a proposed collection alternative on the grounds that the petitioners failed to provide sufficient information, which information was requested multiple times by the IRS. Procedural Background to Nesbitt v. Commissioner

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Scott St. Amand May 18, 2020
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