Procedural Issues
Memorandum Opinions

Crandall v. Commissioner
T.C. Memo. 2021-39

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Crandall v. Commissioner (T.C. Memo. 2021-39). The primary issue presented in Crandall v. Commissioner was whether the parties’ closing agreement precluded the determined deficiency and penalty. Background to Determination in Crandall v. Commissioner During taxable years 2003 through 2011 the petitioners received foreign-source pension income, interest income, and ordinary dividends. For each of those years they paid Italian income tax. 

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Scott St. Amand March 29, 2021
Procedural Issues
Memorandum Opinions

American Limousines Inc. v. Commissioner
T.C. Memo. 2021-36

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of American Limousines Inc. v. Commissioner (T.C. Memo. 2021-36). The primary issues presented in American Limousines Inc. v. Commissioner were whether the IRS abused its discretion in rejecting an installment agreement (that the petitioner could not fund) and whether the IRS abused its discretion in refusing to classify the petitioner’s account as currently not collectible. Background to American Limousines Inc. v. Commissioner

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Scott St. Amand March 24, 2021
Procedural Issues
Memorandum Opinions

Siebert v. Commissioner
T.C. Memo. 2021-34

On March 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Siebert v. Commissioner (T.C. Memo. 2021-34). The primary issue presented in Siebert v. Commissioner was whether the settlement officer abused her discretion in sustaining the proposed collection action A Note on Petitioner’s Appeal in Siebert v. Commissioner I am a big believer in karma.  The petitioners may or may not have had this decision coming.  Here’s a brief summary of why

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Scott St. Amand March 15, 2021
Procedural Issues
Full Tax Court Opinions

Mainstay Business Solutions v. Commissioner
156 T.C. No. 7

On March 4, 2021, the Tax Court issued its opinion in Mainstay Business Solutions v. Commissioner (156 T.C. No. 7). The underlying issue presented in Mainstay Business Solutions v. Commissioner was whether the Tax Court has the discretion to allow a petitioner to withdraw a petition when the petitioner did not invoke the Tax Court’s jurisdiction to redetermine a deficiency. Context to Mainstay Business Solutions v. Commissioner I am a bit delinquent in my summaries. Mea

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Scott St. Amand March 4, 2021
Procedural Issues
Full Tax Court Opinions

McCrory v. Commissioner
156 T.C. No. 6

On March 2, 2021, the Tax Court issued its opinion in McCrory v. Commissioner (156 T.C. No. 6). The underlying issue presented in McCrory v. Commissioner was whether the preliminary award recommendation issued by the IRS’s Whistleblower Office under IRC § 7623(a) constitutes a binding “determination” within the meaning of IRC § 7623(b)(4).  Not so much. Procedural Background to McCrory v. Commissioner The petitioner filed 21 Forms 211 (Application for Award for Original Information) with

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Scott St. Amand March 2, 2021
Procedural Issues
Tax Opinions

Galloway v. Commissioner
T.C. Memo. 2021-24

On February 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Galloway v. Commissioner (T.C. Memo. 2021-24). The primary issue presented in Galloway v. Commissioner was whether, during his CDP hearing, the petitioner was “improperly barred from resuscitating an offer-in-compromise” that had been rejected prior to the NFTL filing. Background to Galloway v. Commissioner By the time his second offer was rejected, the petitioner owed $81,500 in tax for 2014.  In

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Scott St. Amand February 24, 2021
Procedural Issues
Tax Opinions

BM Construction v. Commissioner
T.C. Memo. 2021-13

On February 8, 2021, the Tax Court issued a Memorandum Opinion in the case of BM Construction v. Commissioner (T.C. Memo. 2021-13). The primary issue presented in BM Construction v. Commissioner was whether the IRS had satisfied its burden to prove that the letter in question was mailed and actually received for CDP purposes. Background to BM Construction v. Commissioner IRC § 3406 requires a payor to deduct and withhold tax from certain payments not

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Scott St. Amand February 8, 2021
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