United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court held that a company’s sole shareholder and officer was liable for the company’s unpaid employment taxes and sustained the IRS’s determinations to proceed with lien and levy actions to collect trust fund recovery penalties assessed against her, finding no abuse of discretion by the IRS in making its determinations.

TERRIE ANN HELLMAN,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2013-190

United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court, in a summary opinion, held that an IRS revenue agent failed to substantiate her charitable contribution deductions for donations she allegedly made to a church and held her liable for accuracy-related penalties, finding that she failed to show reasonable cause for the deductions claimed or that she acted in good faith.

Margaret Payne, pro se.

Frederick C. Mutter, for respondent.

T.C. Summ. Op. 2013-64

 

United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court held that an individual is entitled to relief from joint and several liability on a joint tax return, finding that the claim was not barred by res judicata and that the Appeals Office erred in not granting the request for relief.

Melanie E. Marmion, for petitioner.

John D. Davis, for respondent.

T.C. Memo 2013-178

United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court held that the IRS didn’t abuse its discretion in sustaining a proposed levy against an individual who was given an opportunity for a face-to-face hearing to dispute the underlying liability, provided no evidence that the liability was incorrect, and proposed no collection alternatives.

MICHAEL R. GENTILE,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2013-175