Procedural Issues
Memorandum Opinions

Benson v. Commissioner
T.C. Memo. 2021-78

On June 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Benson v. Commissioner (T.C. Memo. 2021-78). The primary issue presented in Benson v. Commissioner was whether the petitioner was precluded from challenging his underlying liabilities in a CDP case. Background to Benson v. Commissioner The petitioner has sought to challenge his 2008 and 2009 tax liabilities both in his CDP hearing and in this Court. The petitioner had two prior

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

Kelly v. Commissioner
T.C. Memo. 2021-76

On June 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelly v. Commissioner (T.C. Memo. 2021-76). The primary issues presented in Kelly v. Commissioner were whether transfers from a company to the petitioner were loans, and if so, whether the petitioner received taxable distributions or cancellation of indebtedness (COD) income when the loans were cancelled. Background to Kelly v. Commissioner The petitioner was a 50% owner of Lucky Bastard Records.

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

Whistleblower 1008416W v. Commissioner
T.C. Memo. 2021-73

On June 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 1008416W v. Commissioner (T.C. Memo. 2021-73). The primary issue presented in Whistleblower 1008416W v. Commissioner was whether the IRS abused its discretion in denying petitioner’s claim for a whistleblower award. Background to Whistleblower 1008416W v. Commissioner In June 2010, the petitioner provided whistleblower information about the target taxpayer (target) to an attorney with respondent’s Office of Chief Counsel and delivered

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Scott St. Amand June 21, 2021
Procedural Issues
Memorandum Opinions

Lufkin v. Commissioner
T.C. Memo. 2021-71

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Lufkin v. Commissioner (T.C. Memo. 2021-71). The primary issue presented in Lufkin v. Commissioner was whether the pro se petitioner was liable for certain Form 941 liabilities. Background to Lufkin v. Commissioner The IRS assessed the Form 941 liabilities, which arose in connection with the petitioner’s law practice, for the periods at issue in December 1998 and June 1999, respectively. After the

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Scott St. Amand June 21, 2021
Procedural Issues
Memorandum Opinions

Verghese v. Commissioner
T.C. Memo. 2021-70

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Verghese v. Commissioner (T.C. Memo. 2021-70). The primary issues presented in Verghese v. Commissioner were (1) whether, under IRC § 6404(a) the petitioners are entitled to abatement on the basis of principles of fairness, and (2) whether under IRC § 6404(e) the IRS engaged in ministerial or managerial acts that constituted unreasonable delay for which the petitioners’ abatement request should

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Scott St. Amand June 21, 2021
Procedural Issues
Full Tax Court Opinions

Stein v. Commissioner
156 T.C. No. 11

On June 17, 2021, the Tax Court issued its opinion in Stein v. Commissioner (156 T.C. No. 11). The primary issue presented in Stein v. Commissioner was whether the Tax Court has discretion to grant the petitioners’ motion to dismiss a stand-alone petition for recovery of administrative costs when the petition did not invoke the Tax Court’s jurisdiction to redetermine a deficiency under IRC § 6213(a). Factual Background in Stein v. Commissioner The petitioners filed an

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

Mason v. Commissioner
T.C. Memo. 2021-64

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Mason v. Commissioner (T.C. Memo. 2021-64). The primary issue presented in Mason v. Commissioner was whether Appeals abused its discretion by reviewing the Centralized Unit’s decision for abuse of discretion instead of reviewing the Masons’ offer on its merits. Background to Mason v. Commissioner: A Lesson in Bureaucracy Victor and Katherine Mason owed back taxes. They didn’t deny it, but

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Scott St. Amand May 26, 2021
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