Procedural Issues
Memorandum Opinions

Chow v. Commissioner
T.C. Memo. 2021-106

On September 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Chow v. Commissioner (T.C. Memo. 2021-106). The primary issue presented in Chow v. Commissioner was whether the IRS’s Whistleblower Office (WBO) abused its discretion when it denied the petitioners’ claim on the basis that the information that they provided was bullshit (rather, “not credible”). Held: No. You people are crazy. Background to Chow v. Commissioner Mr. and Mrs. Wai-Cheung Wilson Chow

Read More »
Scott St. Amand October 5, 2021
Procedural Issues
Memorandum Opinions

Webb v. Commissioner
T.C. Memo. 2021-105

On August 31, 2021, the Tax Court issued a Memorandum Opinion in the case of Webb v. Commissioner (T.C. Memo. 2021-105). The primary issue presented in Webb v. Commissioner was whether Appeals abused its discretion when it declined to place the petitioner in currently not collectible (CNC) status. Background to Webb v. Commissioner On March 4, 2019, the IRS issued to the petitioner a Notice of Intent to Levy and Notice of Your Right to a

Read More »
Scott St. Amand October 4, 2021
Procedural Issues
Memorandum Opinions

Kidz University Inc. v. Commissioner
T.C. Memo. 2021-101

On August 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Kidz University Inc. v. Commissioner (T.C. Memo. 2021-101). The primary issues presented in Kidz University Inc. v. Commissioner were whether the settlement officer: (1) properly verified that the requirements of applicable law or administrative procedure were met; (2) considered any relevant issues Kidz University raised; and (3) considered whether any proposed collection action balances the need for the efficient collection of

Read More »
Scott St. Amand October 1, 2021
Procedural Issues
Memorandum Opinions

Wathen v. Commissioner
T.C. Memo. 2021-100

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Wathen v. Commissioner (T.C. Memo. 2021-100). The primary issues presented in Wathen v. Commissioner were whether the petitioner failed to report income, whether the petitioner is entitled to deductions on Schedule C, whether the petitioner is liable for the failure to file penalty for 2010 and 2011, and whether the petitioner is liable for the substantial understatement accuracy-related penalty. Background to

Read More »
Scott St. Amand September 30, 2021
Procedural Issues
Memorandum Opinions

Mohsen v. Commissioner
T.C. Memo. 2021-99

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Mohsen v. Commissioner (T.C. Memo. 2021-99). The primary issues presented in Mohsen v. Commissioner were whether the Tax Court possessed jurisdiction to decide the taxpayer’s claim for refund and whether the taxpayer’s unpaid income tax liability could be offset by a claimed (time-barred) credit. Filing Background to Mohsen v. Commissioner On April 15, 2002, the petitioner mailed the IRS a

Read More »
Scott St. Amand September 29, 2021
Procedural Issues
Memorandum Opinions

Abraham v. Commissioner
T.C. Memo. 2021-97

On August 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Abraham v. Commissioner (T.C. Memo. 2021-97). The primary issue presented in Abraham v. Commissioner  was whether the settlement officer abused its discretion in rejecting the petitioners’ offer in compromise and by not performing a bankruptcy analysis. Initial Observations about Abraham v. Commissioner Father Abraham three wives—Hagar, Sarah, and Keteurah. Jerry Abraham had one wife. Her name was Debra. The Returns

Read More »
Scott St. Amand September 27, 2021
Procedural Issues
Full Tax Court Opinions

Rogers v. Commissioner
157 T.C. No. 3

On August 2, 2021, the Tax Court issued its opinion in Rogers v. Commissioner (157 T.C. No. 3). The primary issue presented in Rogers v. Commissioner was whether the IRS Whistleblower Office abused its discretion when it rejected/denied the petitioner’s claim. Held: Oh yeah. Side Note One of the attorneys for the IRS is named Bartholomew Cirenza. There’s a fair to middling chance that he has been given more swirlies, wedgies, and other sundry childhood punishments

Read More »
Scott St. Amand September 8, 2021
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