Tax Litigation: The Week of August 1st, 2022, through August 5th, 2022 Eze v. Comm’r, T.C. Memo. 2022-83 | August 4, 2022 | Lauber, J. | Dkt. No. 21425-19...more
Restricted Appeals A restricted appeal is a direct attack on a judgment. To be entitled to a restricted appeal, an appellant must demonstrate several elements described below. ...more
Subject-matter jurisdiction concerns a court’s power to hear a case. Without it, a court does not have authority to decide a case. Subject matter jurisdiction is distinct from the concept of personal jurisdiction, which...more
Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more
Judgments can generally be attacked through either a direct or collateral attack. A collateral attack, as opposed to a direct attack, does not attempt to secure a corrected judgment; rather, it involves an attempt to avoid...more
Ahmed v. Comm’r, T.C. Memo. 2021-142 |December 28, 2021 | Thornton, J. | Dkt. No. 12876-18L -
Short Summary. The IRS filed a notice of federal tax lien against Mr. Ahmed with respect to his 2013, 2014, 2015, and 2016...more
1/21/2022
/ Abuse of Discretion ,
Deficiency Notices ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Jurisdiction ,
Tax Court ,
Tax Levy ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Whistleblowers
Tax Litigation: The Week of December 6 – December 10, 2021 -
Coggin v. Comm’r, 157 T.C. No. 12 | December 8, 2021 | Weiler, J. | Dkt. No. 21580-19 -
Short Summary: Alice J. Coggin (“Coggin”), who was married during...more
The Travel Act, 18 U.S.C. § 1952, makes it a federal crime to travel, use the mail, or use any facility in interstate or foreign commerce for the purpose of furthering an “unlawful activity.”...more
Tax Litigation: The Week of August 23 – August 27, 2021 -
Tax Court Case: Estate of Charles P. Morgan, Deceased, Roxanna L. Morgan, Personal Representative and Roxanna L. Morgan v. Comm’r, T.C. Memo 2021-104 | August 23,...more
9/17/2021
/ Acquisitions ,
Business Taxes ,
Final Determinations ,
Income Taxes ,
Innocent Spouse Exception ,
IRS ,
Joint Tax Returns ,
Jurisdiction ,
Special Purpose Acquisition Companies (SPACs) ,
Startups ,
Tax Court ,
Tax Liability ,
Tax Planning
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of July 5 – July 9, 2021 -
Peterfreund v. Commissioner,...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of October 31 – November 6, 2020 -
Glade Creek Partners,...more
11/12/2020
/ Charitable Deductions ,
Clerical Errors ,
Conservation Easements ,
De Novo Standard of Review ,
Income Taxes ,
IRS ,
Joint and Several Liability ,
Joint Tax Returns ,
Jurisdiction ,
Material Misstatements ,
Scope of Review ,
Spouses ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Underpayment