Procedural Issues
Memorandum Opinions

Hill v. Commissioner
T.C. Memo. 2021-121

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Hill v. Commissioner (T.C. Memo. 2021-121). The primary issue presented in Hill v. Commissioner was whether the petitioner’s remittance of $10.3 million to the IRS to be applied toward an anticipated gift tax liability for 2011, which remittance was designated as a “deposit” was a “deposit” or a “payment” for purposes of determining whether interest was due to the petitioner.

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Scott St. Amand November 10, 2021
Procedural Issues
Full Tax Court Opinions

Insinga v. Commissioner
157 T.C. No. 8

On October 27, 2021, the Tax Court issued its opinion in Insinga v. Commissioner (157 T.C. No. 8). The primary issue presented in Insinga v. Commissioner was whether the Tax Court’s jurisdiction over a whistleblower petition filed under IRC § 7623(b)(4) was extinguished by the death of the petitioner-whistleblower. Held: Heck no; whistle on whistler. Background to Insinga v. Commissioner Pursuant to IRC § 7623(b)(4), the petitioner filed a timely petition in the Tax Court

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Scott St. Amand November 1, 2021
Penalties Under the Code
Memorandum Opinions

Crim v. Commissioner
T.C. Memo. 2021-117

On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Crim v. Commissioner (T.C. Memo. 2021-117). The primary issue presented in Crim v. Commissioner was whether the penalties assessed against the petitioner for promotion of abusive tax shelters under IRC § 6700(a) were assessed the period of limitations on assessment had expired. Author’s Note: If you read nothing else, I beg you to read the Post Script, where I describe the

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Scott St. Amand October 22, 2021
Procedural Issues
Memorandum Opinions

McCrory v. Commissioner
T.C. Memo. 2021-116

On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of McCrory v. Commissioner (T.C. Memo. 2021-116). The primary issue presented in McCrory v. Commissioner was whether the IRS Whistleblower Office’s rejections of the petitioner’s claims were unsupported by the administrative record and were arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law. Background to Whistleblower Claims in McCrory v. Commissioner The petitioner submitted six Forms 211

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Scott St. Amand October 20, 2021
Procedural Issues
Memorandum Opinions

Whistleblower 1437716W v. Commissioner
T.C. Memo. 2021-113

On September 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 1437716W v. Commissioner (T.C. Memo. 2021-113). The primary issues presented in Whistleblower 1437716W v. Commissioner were whether the whistleblower could proceed anonymously, and whether the WBO abused its discretion in denying the whistleblower-petitioner an award. Held: Nope on both counts. Background to “Old 77” Whistleblower and Whistleblower 1437716W Peter J. Reilly, a Forbes tax contributor, nicknamed the whistleblower in Whistleblower 1437716W

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Scott St. Amand October 12, 2021
Procedural Issues
Memorandum Opinions

Brown v. Commissioner
T.C. Memo. 2021-112

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Brown v. Commissioner (T.C. Memo. 2021-112). The sole issue presented in Brown v. Commissioner was whether the Tax Court has jurisdiction to order the refund of a TIPRA payment. What is a TIPRA Payment? The Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA), Pub. L. No. 109-222, § 509(a), enacted new IRC § 7122(c), effective for offers-in-compromise (OICs) submitted on

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Scott St. Amand October 11, 2021
Procedural Issues
Memorandum Opinions

Pazden v. Commissioner
T.C. Memo. 2021-108

On September 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Pazden v. Commissioner (T.C. Memo. 2021-108). The primary issues presented in Pazden were (1) whether Ms. Pazden is entitled to challenge her underlying tax liability for 2010, and (2) whether Appeals abused its discretion in sustaining the proposed levy in this case. Held: Nope and Nope. Background Ms. Pazden failed to timely file her 2010 Federal income tax return. The

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Scott St. Amand October 7, 2021
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