Income Tax Issues
Tax Opinions

Staples v. Commissioner
T.C. Memo. 2020-34

On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount he received as Social Security Disability Insurance (SSDI) benefits. Background to Staples v. Commissioner The petitioner worked for the USPTO until disability forced him to

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Scott St. Amand March 11, 2020
Procedural Issues
Tax Opinions

Thomas v. Commissioner
T.C. Memo. 2020-33

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Thomas v. Commissioner (T.C. Memo. 2020-33). The single issue presented in Thomas v. Commissioner was whether the petitioners timely filed their petition within the time prescribed by IRC § 6213(a) or IRC § 7502, which in turn depended on whether a private postmark bearing a previous date to the USPS postmark was controlling. Background to Thomas v. Commissioner In November

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Scott St. Amand March 5, 2020
Procedural Issues
Tax Opinions

Wong v. Commissioner
T.C. Memo. 2020-32

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Wong v. Commissioner (T.C. Memo. 2020-32). The single issue presented in Wong v. Commissioner was whether Wong was right, which is to say, whether the IRS’s determination to sustain the collection action against the petitioner was proper as a matter of law. Background to Wong v. Commissioner Petitioner, Do Wong, filed a timely Federal income tax return for 2013, reporting

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Scott St. Amand March 5, 2020
Procedural Issues
Tax Opinions

Liu v. Commissioner
T.C. Memo. 2020-31

On March 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Liu v. Commissioner (T.C. Memo. 2020-31). The single issue presented in Liu v. Commissioner was whether the Tax Court had jurisdiction to determine whether petitioners were liable for interest on the deficiencies determined by the IRS because the IRS filed an erroneous notice of Federal tax lien (NFTL). Background to Liu v. Commissioner Petitioners each owned a 50% interest in

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Scott St. Amand March 5, 2020
Procedural Issues
Tax Opinions

Pulcine v. Commissioner (T.C. Memo. 2020-29)

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Pulcine v. Commissioner (T.C. Memo. 2020-29). The primary issue presented in Pulcine was whether a whistleblower, whose report initiated an audit of the alleged bad actor, which ultimately resulted in the “bad actor” receiving a refund on his return, demonstrated that the IRS’s Whistleblower Office (WBO) abused its discretion in not awarding the whistleblower for his information.

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Scott St. Amand March 2, 2020
Procedural Issues
Tax Opinions

Alber v. Commissioner
T.C. Memo. 2020-20

On January 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Alber v. Commissioner (T.C. Memo. 2020-20). The issue presented in Alber v. Commissioner was whether the Whistleblower Office of the IRS abused its discretion in summarily rejecting a whistleblower’s claim on the basis that the information provided to support such claim was speculative and/or did not provide specific or credible information regarding tax underpayments or violations of internal revenue laws.

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Scott St. Amand January 30, 2020
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