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 United States Tax Court granted the IRS summary judgment in a couple’s challenge of their tax liabilities and of the IRS’s denial of their installment agreement request, finding no abuse of discretion since the couple failed to explain discrepancies in their reported assets despite being given several opportunities to do so.

ANTONIO J. AREDE AND GILVELY COALHO AREDE,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-29

 

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 United States Tax Court upheld additions to tax under section 6651 and section 6654 against an individual who failed to pay income tax for three years, and imposed a $10,000 penalty under section 6673(a)(1), finding that the individual brought suit to delay collection and made frivolous arguments.

DAVID K. WINTERROTH,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-28

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 a neurosurgeon’s work-related expenses are deductible as itemized deductions subtracted from her adjusted gross income in the computation of her taxable income on Schedule A, finding that she did not show that she practiced medicine under circumstances other than as an employee.

ELIZABETH A. VITARBO,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent