The IRS’s budget constraints have made it more difficult for taxpayers to resolve IRS problems. This is especially true for the work that it has shifted to IRS service centers to be worked remotely. The Wang v. Commissioner, T.C. Memo. 2016-123, case provides an example of this. Mr. Wang is a real estate agent for […]
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In Buffano v. United States, T.C. Memo. 2016-122, the U.S. Tax Court concluded that that the taxpayer was not liable for tax because the IRS failed to properly assess the tax because the IRS did not mail notices of the tax deficiencies to the taxpayer’s last known address. This case is a good example of […]
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In Marshall v. Commissioner, T.C. Memo. 2016-119, the U.S. Tax Court concluded that business owners who sold their stock was liable for the buyer’s Federal income taxes that arose after the sale. The facts and procedural history are as follows: The taxpayers owned Marshall Associated Contractors, Inc. (MAC), which was subject to tax as a […]
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In Finnegan v. Commissioner, T.C. Memo. 2016-118, the U.S. Tax Court refused to reconsider its previous decision that a tax return preparers fraud keeps the statute of limitations open on the taxpayer’s Federal income tax return. The facts and procedural history are as follows: On February 7, 2013, the IRS issued a notice of deficiency […]
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The IRS has broad collection powers. It is always interesting to see cases where other creditors are able to collect despite the IRS’s collection powers. The U.S. v. Heptner, Case No. 8:15-cv-1125-T-33MAP case provides an example. In Heptner the U.S. District Court in Tampa concluded that a loan from the taxpayer’s former employer trumped the […]
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