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. …..
Cases before the U.S. Tax Court are often won or lost by whether evidence is or is not admitted in the record. Lunnon v. Commissioner, No. 15-9007 (10th Cir.), provides an example of how this works in a tax collections …..
In Sloan v. Commissioner, T.C. Memo. 2016-115, the U.S. Tax Court refused to apply transferee liability under Section 6901 to make a taxpayer who sold company assets to a third party liable for the third party’s tax liability. The court …..
In Belot v. Commissioner, T.C. Memo. 2016-113, the U.S. Tax Court concluded that the sale of businesses to a former spouse was not taxable even though the sale occurred more than a year after the parties were divorced. The facts …..
In Duckett v. Enomoto, Dkt No. 2:14-cv-01771, the U.S. District Court in Arizona concluded that a Federal tax lien for taxes owed by a trust beneficiary did not attach to the entire trust. This issue often comes up in IRS …..
In Stein, LLC, v. United States, No. 2:13-03224, the United States District Court for the Western District of Louisiana addressed the question of whether refund claims stemming from loss carrybacks include computational adjustments in the carryback years. This type of …..
In Ax v. Commissioner, 146 T.C. No. 10, the U.S. Tax Court held that the IRS could raise new arguments in court for the first time in deficiency cases despite the Administrative Procedure Act. This case confirms that the IRS’s …..