Procedural Issues
Tax Opinions

Chang v. Commissioner
T.C. Memo. 2020-19

On January 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Chang v. Commissioner (T.C. Memo. 2020-19). The issues presented in Chang v. Commissioner were (1) whether petitioners timely mailed requests for CDP hearings; and if so (2) whether the Tax Court had jurisdiction to review the subsequent decision letters issued by the IRS. Equivalent Hearing in Chang v. Commissioner Where a person does not timely request a Collection Due Process

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Scott St. Amand January 29, 2020
Procedural Issues
Tax Opinions

Northside Carting Inc. v. Commissioner
T.C. Memo. 2020-18

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Northside Carting Inc. v. Commissioner (T.C. Memo. 2020-18). The primary issue presented in Northside Carting Inc. v. Commissioner was whether the IRS abused its discretion by rejecting collection alternatives (an installment agreement) raised in an equivalent hearing. Background to Northside Carting Inc. v. Commissioner The petitioner’s business is garbage and has been garbage since 1996. At the time the petition was

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Scott St. Amand January 23, 2020
Business Related Issues
Tax Opinions

Manroe v. Commissioner
T.C. Memo. 2020-16

On January 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Manroe v. Commissioner (T.C. Memo. 2020-16). The issue presented in Manroe v. Commissioner was whether the Tax Court had jurisdiction over the partners to redetermine the penalties at issue in a partner-level proceeding. Background to Manroe v. Commissioner The case stems from a tax shelter transaction, in which the petitioners ultimately conceded that the partnership at issue was a sham,

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Scott St. Amand January 22, 2020
Income Tax Issues
Tax Opinions

Onyeani v. Commissioner
T.C. Memo. 2020-15

On January 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Onyeani v. Commissioner (T.C. Memo. 2020-15). The issue presented in Onyeani v. Commissioner was whether the IRS appropriately issued a termination assessment against the petitioner and determined that his illegal income was taxable. Note on Onyeani v. Commissioner Hello, dear reader, I am Ogorji Timothy Wilson Onyeani, a Nigerian doctor, who has come upon a sum of money in the

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Scott St. Amand January 16, 2020
Income Tax Issues
Tax Opinions

Aviles v. Commissioner
T.C. Memo. 2020-12

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Aviles v. Commissioner (T.C. Memo. 2020-12). The issue presented in Aviles v. Commissioner was whether the Tax Court should revisit its holding in Giamelli v. Commissioner, 129 T.C. 107 (2007), thereby permitting a petitioner, who failed to challenge his underlying tax liability at a CDP hearing, to raise the challenge for the first time in Tax Court. Challenging Underlying Tax

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Scott St. Amand January 14, 2020
Procedural Issues
Tax Opinions

Seely v. Commissioner
T.C. Memo. 2020-6

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Seely v. Commissioner (T.C. Memo. 2020-6). The issue presented in Seely v. Commissioner was whether the taxpayers provided sufficient extrinsic evidence to demonstrate the timely mailing of a petition, even though the envelope in which the petition was mailed bore no postmark. If so, then the Tax Court had jurisdiction to redetermine the deficiency.  If not, then no jurisdiction would

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

Chicago Baseball Holdings LLC v. Commissioner
T.C. Memo. 2020-2

On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Chicago Baseball Holdings LLC v. Commissioner (T.C. Memo. 2020-2). The issue presented in Chicago Baseball Holdings LLC v. Commissioner was whether prior written supervisory approval of penalties was required before the IRS communicates the penalties to the taxpayer for the first time, even if such communication was informal. Jurisdiction in Chicago Baseball Holdings LLC v. Commissioner The Tax Court has jurisdiction

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Scott St. Amand January 6, 2020
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