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 amounts reported as withheld by a couple’s company during a criminal tax trial are credible for determining the actual amounts withheld after the company records were lost.

AMES R. DIXON,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

SHARON C. DIXON,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2013-207

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, granting the IRS summary judgment, held that an IRS settlement officer didn’t abuse his discretion in determining an individual’s reasonable collection potential, rejecting collection alternatives, and sustaining a proposed levy to collect the individual’s unpaid trust fund recovery penalties.

CHARLES M. GLOSSOP,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2013-208