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 a settlement officer didn’t abuse her discretion by making a determination to sustain IRS lien and levy actions against a couple for unpaid tax liabilities, finding that the couple, who didn’t respond to the IRS’s motion for summary judgment, failed to show the existence of any material facts in dispute.

ROBERT TRIOLA AND NANCY V. TRIOLA,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-166

 

 

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 imposed a $10,000 penalty under Internal Revenue Code section 6673(a)(1) against a taxpayer who litigated his income tax liability in the tax court and federal courts, holding that he was previously warned against making frivolous arguments; the court also granted the IRS summary judgment in the collection action.

ALVIN SHELDON KANOFSKY,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,  Respondent

T.C. Memo. 2014-153

 

 

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 dismissed an individual’s challenge to the IRS’s proposed levy actions for two tax years, finding that the court lacked jurisdiction, and granted the IRS summary judgment regarding a levy for a third tax year, finding that she had failed to respond to the motion and there was no abuse of discretion by the IRS.

JANET MCCULLAR,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2014-150