Procedural Issues
Memorandum Opinions

Richlin v. Commissioner
T.C. Memo. 2020-60

On May 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Richlin v. Commissioner (T.C. Memo. 2020-60). The issues before the court in Richlin v. Commissioner were (1) whether Form 12257 (Summary Notice of Determination, Waiver of Right to Judicial Review of a Collection Due Process Determination, and Waiver of Suspension of Levy Action) is a binding contract between the petitioner and the IRS; (2) whether IRM 8.22.9.13 prohibits rescission of

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

Kirkley v. Commissioner
T.C. Memo. 2020-57

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Kirkley v. Commissioner (T.C. Memo. 2020-57). The primary issue before the court in Kirkley v. Commissioner was whether the IRS’s determination that petitioners must liquidate all of their property, including their residence, as a condition for the IRS’s acceptance of an installment agreement, was a (rather egregious) abuse of discretion. Statement of Facts in Kirkley v. Commissioner The common perception

Read More »
Scott St. Amand May 13, 2020
Procedural Issues
Tax Opinions

Kansky v. Commissioner
T.C. Memo. 2020-43

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Kansky v. Commissioner (T.C. Memo. 2020-43). The issue properly before the court in Kansky v. Commissioner was whether the Whistleblower Office of the IRS abused its discretion in rejecting the petitioner’s claim on the basis that it was speculative and did not provide specific or credible information regarding a violation of the Federal tax laws. Background to the Claim in

Read More »
Scott St. Amand April 13, 2020
Procedural Issues
Tax Opinions

Lewis v. Commissioner
154 T.C. No. 8

On April 8, 2020, the Tax Court issued its opinion in Lewis v. Commissioner (154 T.C. No. 8). The issue presented in Lewis v. Commissioner was whether the IRS abused its discretion in the computation of his award by excluding reported, paid tax from the collected proceeds and by determining that there was no possibility of future proceeds relating to the deceased target taxpayer’s estate. Background to Lewis v. Commissioner The moral of the story

Read More »
Scott St. Amand April 8, 2020
Procedural Issues
Tax Opinions

Goldberg v. Commissioner
T.C. Memo. 2020-38

On April 2, 2020, the Tax Court issued a 163-page Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2020-38). The issues properly before the court in Goldberg v. Commissioner were whether Form 4549 (Income Tax Examination Changes) is a binding contract and whether the interest under IRC § 6404(e)(1) should be abated. A number of other issues including collateral and equitable estoppel were raised, but the Tax Court found that they were

Read More »
Scott St. Amand April 2, 2020
Procedural Issues
Tax Opinions

Cline v. Commissioner
T.C. Memo. 2020-35

On March 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Cline v. Commissioner (T.C. Memo. 2020-34). The issue presented in Cline v. Commissioner was whether the IRS Whistleblower Office (WBO) abused its discretion when it denied the petitioners claims against a taxpayer because such claims failed to provide specific and credible information regarding tax underpayments or violations of internal revenue laws. Background to Cline v. Commissioner The petitioner alleged that

Read More »
Scott St. Amand March 16, 2020
Procedural Issues
Tax Opinions

Lander v. Commissioner
154 T.C. No. 7

On March 12, 2020, the Tax Court issued its opinion in Lander v. Commissioner (154 T.C. No. 7). The issue presented in Lander v. Commissioner was whether the petitioners, who did not receive the statutory notice of deficiency (SNOD) mailed to their last known address, could challenge their underlying tax liability in a collection due process (CDP) proceeding. Public Service Announcement from Lander v. Commissioner You may have come to this post because you are

Read More »
Scott St. Amand March 12, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular posts:

Redefining Your Financial Outlook for Greater Life Success
Guest Post

Redefining Your Financial Outlook for Greater Life Success Guest Writer:  Michael Longsdon of ElderFreedom.net* It’s a powerful realization that our financial success is deeply intertwined with our money mindset. This article will guide you through the steps to rewire your perception of money and to redefine your financial outlook, opening

Read More »
Scott St. Amand November 28, 2023

Ultimate Guide to Managing Business Finances for Entrepreneurs
Guest Post

Guest Writer:  Michael Longsdon of ElderFreedom.net* As an entrepreneur, managing the finances of your business can be a daunting task, which is why this Guide to Managing Business Finances for Entrepreneurs was created. It is not uncommon to feel overwhelmed, especially if you lack experience in finance. However, good financial

Read More »
Scott St. Amand June 26, 2023

Norberg v. Commissioner
T.C. Memo. 2022-30

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Norberg v. Commissioner (T.C. Memo. 2022-30). The primary issue presented in Norberg v. Commissioner was whether the settlement officer abused its discretion in upholding a notice of intent to levy and denying the petitioners’ request

Read More »
Scott St. Amand January 24, 2023

Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied;

Read More »
Scott St. Amand November 23, 2022