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

Accountant’s Law School Tuition Was Not a Deductible Expense

The United States Tax Court, declining to reconsider the validity of reg.section 1.162-5(b)(1), held that an accountant who prepared returns and provided other financial services for clients couldn’t deduct his tuition and fees for law school, finding that law school qualified him for a new trade or business as described in the regulation.

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.

EMMANUEL A. SANTOS,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2016-100

 

 

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

No Abuse of Discretion by Settlement Officer; the IRS Levy is Sustained

The United States Tax Court sustained a proposed levy action against an individual who claimed her 1991 bankruptcy discharge relieved her of paying future taxes; the court upheld the IRS’s determinations regarding her underlying tax liabilities and found that the settlement officer didn’t abuse his discretion in sustaining the collection action.

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.

GINN DOOSE A.K.A.VIRGINIA DOOSE,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2016-89

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

No IRS Abuse of Discretion by Appeals Settlement Offer in Rejecting Offer in Compromise, Proceeding With Collection

The United States Tax Court sustained a proposed IRS collection action against an individual and upheld the IRS’s rejection of his offer in compromise, finding no abuse of discretion by the IRS because the individual’s offer was well below his reasonable collection potential, which included dissipated retirement account assets.

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.

ERIC EDWARD CHANDLER,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2015-215