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 found insufficient evidence to determine whether the IRS Appeals Office failed to properly consider an individual’s health when rejecting his compromise offer and sustaining the filing of a tax lien notice against him; thus, the court remanded the collection due process case for clarification and to supplement the record.

LARRY F. ANDERSON,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2013-261

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 a fugitive liable for a fraud penalty for one tax year, finding that there was clear and convincing evidence of his fraudulent intent to underpay his taxes, but declined to a impose a fraud penalty or addition to tax for fraudulent failure to file for another year, finding that his return signed by his partner was invalid.

ABDALLA MOHAMED,

Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2013-255