Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, Judge | Dkt. Nos. (Consolidated)...more
Tax Litigation: The Week of July 11th, 2022, through July 15th, 2022 Colbert v Commissioner, T.C. Memo. 2022-74 | July 13, 2022 |Wells, J.| Dkt. No. 8395-16. Knight v. Comm’r, T.C. Memo. 2022-76| July 14, 2022 | Lauber, A. |...more
Tax Litigation: The Week of June 27th, 2022, through July 1st, 2022 Serna v Commissioner, T.C. Memo. 2022-66 | June 27, 2022 | Urda, J.| Dkt. No. 13202-19L Pedersen v. Commissioner, T.C. Summary Opinion 2022-11 | June 28,...more
Under the Internal Revenue Code, the IRS can satisfy a tax deficiency by imposing a lien on any “property” or “rights to property” belonging to the taxpayer. The statutory language is broad and reaches virtually every...more
Tax Litigation: The Week of March 14, 2022, through March 18, 2022 AptarGroup, Inc. v. Comm’r, 158 T.C. No. 4 | March 16, 2022 |Goeke, J. | Dkt. No. 7218-2 Pickens Decorative Stone, LLC v. Comm’r, T.C. Memo. 2022-22 | March...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....more
2/7/2022
/ Deficiency Notices ,
ESOP ,
Fiduciary Duty ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Court ,
Tax Liability ,
Tax Liens ,
Tax Planning ,
Tax Returns
Can you be held liable for a tax liability owed by another taxpayer? Yes, under certain circumstances. The IRS uses fraudulent transfer law and “transferee” liability tools to collect unpaid taxes where a taxpayer has...more
12/8/2021
/ Criminal Liability ,
Department of Justice (DOJ) ,
FDCPA ,
Fraudulent Transfers ,
Income Taxes ,
IRS ,
Tax Liability ,
Tax Liens ,
Tax Planning ,
Transfer of Assets ,
Transferees ,
UFTA
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 August 2 – August 6, 2021 - Belair v. Comm’r, Bench Opinion|...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 January 25 – January 29, 2021 -
Costello v. Comm’r, T.C....more
2/8/2021
/ Abuse of Discretion ,
Charitable Deductions ,
Farms ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Rental Income ,
Rental Property ,
Startups ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Liens ,
Tax Returns
IRS debt can be a life-changing burden. But for some taxpayers, an offer in compromise may be an avenue to get rid of that tax debt and to receive a fresh start. When a taxpayer qualifies for an offer in compromise, the IRS...more
Along with tax penalties and tax lien filings, the IRS’s ability to seize a taxpayer’s property is one of its most potent weapons to encourage tax compliance. That is, in part, what makes a recent report from the Treasury...more