Procedural Issues
Memorandum Opinions

Estate of Lee v. Commissioner
T.C. Memo. 2021-92

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Lee v. Commissioner (T.C. Memo. 2021-92). The primary issue presented in Estate of Lee v. Commissioner was whether the IRS abused its discretion in rejecting the petitioner’s offer-in-compromise by erring to properly compute the estate’s reasonable collection potential by including amounts distributed by the executor. Challenging the IRS Lien before Appeals in Estate of Lee v. Commissioner IRC §

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Scott St. Amand September 2, 2021
Procedural Issues
Procedural Issues

Belair v. Commissioner
157 T.C. No. 2

On August 2, 2021, the Tax Court issued its opinion in Belair v. Commissioner (157 T.C. No. 2). The primary issue presented in Belair v. Commissioner  was whether in a CDP nonliability case the traditional rules of summary judgment are appropriate. Holding in Belair v. Commissioner In a CDP nonliability case such as this, the Tax Court’s decision turns on whether the administrative record shows an abuse of discretion, and the Tax Court’s traditional rules of

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Scott St. Amand August 31, 2021
Procedural Issues
Memorandum Opinions

Morreale v. Commissioner
T.C. Memo. 2021-90

On July 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Morreale v. Commissioner (T.C. Memo. 2021-90). The primary issue presented in Morreale v. Commissioner was whether the petitioner was entitled for reasonable litigation fees from the IRS. Background to Morreale v. Commissioner The petitioner filed a Tax Court petition in November 2017 disputing certain adjustments to his return. The petitioner and the IRS settled in January 2019, with the IRS

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Scott St. Amand August 3, 2021
Procedural Issues
Memorandum Opinions

Mathews v. Commissioner
T.C. Memo. 2021-85

On July 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-85). The primary issue presented in Mathews v. Commissioner was whether the Tax Court had jurisdiction to hear a petitioner when the pro se petitioner filed his petition (sent a letter to the Tax Court) well after the 90 day deadline had passed, and whether because the Tax Court had jurisdiction over one year’s petition,

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

Peterfreund v. Commissioner
T.C. Memo. 2021-83

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Peterfreund v. Commissioner (T.C. Memo. 2021-83). The primary issue presented in Peterfreund v. Commissioner  was whether the IRS’s Whistleblower Office (WBO) abused its discretion because it did not initiate an administrative or judicial action and it did not collect any proceeds from the target taxpayer on the basis of the information the petitioner furnished. Whistleblowin’ Jurisdiction as told by Peterfreund

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

Pragias v. Commissioner
T.C. Memo. 2021-82

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Pragias v. Commissioner (T.C. Memo. 2021-82). The primary issue presented in Pragias v. Commissioner was whether the six-year statute of limitations under IRC § 6501(e) (substantial omission of items) applied. The Substantial Omission Extension under IRC § 6501(e) in Pragias v. Commissioner IRC § 6501(a) generally requires that the IRS assess tax within three years after the taxpayer files his

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

Long v. Commissioner
T.C. Memo. 2021-81

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Long v. Commissioner (T.C. Memo. 2021-81). The primary issue presented in Long v. Commissioner was whether the petitioner was entitled to dispute her underlying liabilities when she failed to do so with prior opportunity arising out of a notice of deficiency that was mailed to the petitioner’s last known address—which she did not receive. Underlying Liability in CDP Case in

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Scott St. Amand July 12, 2021
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