Top 5 Tax Controversy CPA Profiles/Linkedin

J  FRANK BEST CPA/U.S. TAX COURT LITIGATOR

One of the Top 5 Tax Controversy CPA Profiles/Linkedin.

https://www.linkedin.com/title/tax-controversy-cpa

bestirscpa.com

Telephone: 800.230.7090 | Email: bestcpa@bestirscpa.com

 

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

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

The United States Tax Court Upholds Deficiency, Notice of Federal Tax Lien and No IRS Abuse of Discretion Found

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, affirmed an assessment of income tax deficiency and sustained a notice of federal tax lien because the Tax Court found no abuse of discretion by the IRS, noting that the taxpayer had a prior opportunity to contest his tax liability but neglected to do so.

BRIAN CRAIG JOHNSON,

Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Summ. Op. 2014-90