United States Tax Court Decision for the Week – You be the Judge

Unsubstantiated Business Deductions Denied; Penalties Upheld

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 State Tax Court, upholding accuracy-related penalties, sustained the IRS’s disallowance of an individual’s deductions for unsubstantiated employee business expenses for his work with a publishing company but allowed the individual to deduct mileage expenses for traveling to county courthouses around the state to build his law practice.
MARTY DALE MARTIN,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent
 
T.C. Memo. 2016-189

United States Tax Court Decision for the Week – You be the Judge

The United States Tax Court Dismisses Untimely Petition Challenging Collection

The Tax Court dismissed for lack of jurisdiction a couple’s petition challenging a collection determination, finding that it wasn’t filed within the 30-day period provided in section 6330, and the couple failed to show that it was mailed within the 30-day period to be considered timely filed under section 7502.

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.

BRUCE EDWARD HADDIX AND RAE ANN HADDIX,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2015-220

United States Tax Court Decision for the Week – You be the Judge

Lien Action Upheld; No IRS Abuse of Discretion in Denying Face-to-Face Hearing

The  United States Tax Court held that the IRS didn’t abuse its discretion by sustaining a proposed lien action against an individual to collect unpaid taxes and penalties, finding that the IRS settlement officer properly rejected the individual’s request for a face-to-face hearing because he didn’t provide requested documents and financial information.

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.

KENNETH A. MCRAE,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2015-132

United States Tax Court Decision for the Week – You be the Judge

Individual With Unreported Unemployment Income Denied Spousal Relief

The United States Tax Court sustained an IRS deficiency determination against a couple, finding that the couple failed to report as income unemployment compensation the husband received; the court denied the husband’s request for innocent spouse relief, rejecting his unsupported claim that his estranged wife received and cashed the checks without his knowledge.

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.

ALBERT ARIAS AGUDELO,
Petitioner,
AND CECILIA ARIAS,
Intervenor
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2015-124

United States Tax Court Decision for the Week – You be the Judge

Doctor Loses His Challenge to Trust Fund Penalty Collection. No Abuse of Discretion by IRS.

The United Tax Court sustained a proposed IRS levy to collect trust fund recovery penalties from a doctor, whose medical practice failed to pay its employment taxes, finding that he was liable for the penalties and that there was no abuse of discretion by the IRS Appeals Office Settlement Officer; the court denied the doctor’s requests for interest abatement and remand.

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.

IFEANYI OBIAKOR,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2015-112

United States Tax Court Decision for the Week – You be the Judge

United States Tax Court Upholds Lien, Levy Actions Against Tax Scheme Promoter, and Finds No IRS Abuse of Discretion

The  United States Tax Court found no IRS Abuse of Discretion by an Appeals Settlement Officer and upheld IRS lien and levy actions against an individual who promoted and sold abusive tax schemes, finding that she wasn’t entitled to challenge the underlying liabilities because the individual didn’t participate in the collection proceedings or provide a collection alternative.

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.

KATHLEEN KAHN,
Petitioner(s),
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

United States Tax Court Decision for the Week – You be the Judge

No IRS Abuse of Discretion by IRS Appeals Office and Couple Penalized for Frivolous Arguments in Collection Challenge

The United States Tax Court upheld the IRS’s determination to sustain a notice of federal tax lien filing against a couple and imposed a $3,500 penalty against them for advancing frivolous arguments, finding that the IRS’s decision to sustain its proposed collection action was proper as a matter of law. Summary Judgment granted.

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.

GEORGE H. PATTON AND FELOMINA F. PATTON,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2015-75