Earlier this month the Tax Court issued its Opinion in Alon Farhy v. Commissioner of Internal Revenue, 160 T.C. No. 6 (T.C. April 3, 2023), holding that the IRS lacks statutory authority to assess penalties under IRC section 6038(b)(1) or (2) against the petitioner in...
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Tax Court
Watch Your Offshore Assets! Tax Court Increases Incentive for Whistleblowers
Be careful who you share your offshore account information with---whistleblowing just got more lucrative. On August 3, 2016, the US Tax Court issued an opinion in a whistleblower claim case finding that the whistleblowers were entitled to an award based...
Tax Court Re-Affirms Subpoena Notification Requirement, To IRS’ Dismay
On July 8, 2016, Judge Mark V. Holmes issued an order in US Tax Court case Ernest S. Ryder & Associates, Inc., APLC, et al., v. Commissioner requiring the Internal Revenue Service (IRS) to notify the taxpayer of any and all subpoenas, with their responses and...
Tax Court Proposes New Rules Related to IRS Passport Revocation
The United States Tax Court Chief Judge Michael B. Thornton recently announced that the Tax Court has adopted interim amendments and has issued proposed amendments to the Tax Court Rules of Practice and Procedure relating to the Bipartisan Budget Act of 2015, the...
VIDEO: What happens when parties cannot reach a settlement?
In many of the cases we handle, our tax attorneys are able to reach a settlement through negotiations with the other side. However, this isn't always possible, especially if the parties simply do not agree on an issue, or the issue involves an area of law that is...
Tamara Ashford confirmed by the Senate as a Tax Court judge.
Tamara Ashford, who is currently acting assistant attorney general in the Tax Division of the U.S. Department of Justice, was confirmed as a Tax Court Judge by voice vote.Ms. Ashford is currently Assistant Attorney General of the DOJ's Tax Division. At her Senate...
Tax Court rejects proposed addition to tax for fraudulent failure to file
In Kernan v. Commissioner, T.C. Memo. 2014-228, the Tax Court sustained the IRS's proposed deficiencies and additions to for tax years 2001 through 2006 due to the taxpayer's failure to file income tax returns. However, the Court rejected the IRS's proposed penalties...
Court finds settlement proceeds from mortgage fraud lawsuit were not includible in income
In a Summary Opinion, the Tax Court found that a taxpayer did not have $10,000 in unreported income with regard to settlement proceeds resulting from a mortgage fraud lawsuit. Kadir v. Commissioner, T.C. Summ. Op. 2014-43.In Kadir, the taxpayer had refinanced his...
Taxpayers can waive the attorney-client privilege by raising good faith and state-of-mind defenses during litigation
The Tax Court recently issued an opinion in AD Investment v. Commissioner, 142 T.C. No. 13, in which the Court granted the IRS's motion to compel the production of documents. The controversy arose in the context of two consolidated Tax Court proceedings involving...
