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, in a summary opinion, held that an individual who intervened in his former wife’s spousal relief case has standing to seek summary judgment. The court denied his motion for summary judgment, finding that a state court decision in their divorce proceedings didn’t collaterally estop the former wife from seeking relief.

Stephanie Lynn Christie, a.k.a. Stephanie Lynn Foran, pro se.

John Foran, a.k.a. Arthur J. Maurello, pro se.

John Schmittdiel and Melissa J. Hedtke, for respondent.

 

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 held that the IRS abused its discretion by failing to adequately consider a couple’s proposed collection alternative and, citing an undeveloped record, remanded their case so the IRS can determine whether to compromise their tax liability to promote effective tax administration on public policy and equity grounds.

Scott Alan SchumacherJohn Alfred Clynch, Jr., and Emily J. Yamada, for petitioners.

Lisa M. Oshiro, for respondent.

T.C. Memo. 2014-46

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 remanded to IRS Appeals for further consideration a case in which an appeals officer made an erroneous determination in favor of a taxpayer who failed to participate in proceedings against her, rejecting the IRS’s request to find the officer abused his discretion and declining to invalidate the IRS’s supplemental notice and uphold its notice of federal tax liens for six tax years.

JUDY MACDONALD,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-42

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, in a summary opinion, held that the IRS did not abuse its discretion when it rejected a college professor’s proposed installment plan and determined to proceed with a levy to collect his unpaid taxes, finding that the installment payment amount determined by the settlement officer was reasonable and a face-to-face hearing wasn’t required.

MERWIN K. SIGALE,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Summ. Op. 2014-19

 

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 the IRS Appeals Office’s decision to proceed with a proposed levy to collect an individual’s income tax liabilities, finding that he was barred from challenging the existence or amounts of his underlying tax liabilities and that the IRS didn’t abuse its discretion in denying his request for an installment agreement.

ROBERT ALAN LYONS,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-32