Category: Trust Fund Recovery Penalty

Chadwick v. Comm’r

Abstract Case Name: Chadwick v. Comm’r of Internal Revenue, 154 T.C. 84 (Jan. 21, 2020).Jurisdiction: U.S.T.C.Petitioner: David J. ChadwickRespondent: Commissioner of the Internal Revenue Service.Concepts: Penalties and Addition Tax; Trust Fund Recovery Penalty; Summary Judgement; & Judicial Standard of Review.Nature of Case: Whether written supervisor approval is required for trust fund recovery penalties to be collected against […]

Barnhill v. Comm’r

Abstract Case Name: Rickey B. Barnhill v. Commissioner, 155 T.C. No. 1 (July 21, 2020).Jurisdiction: U.S.T.C.Petitioner: Rickey B. Barnhill.Respondent: Commissioner of the Internal Revenue Service.Concepts: Penalties and Addition Tax; Collections; Summary Judgment; Levy or Distraint; Judicial Remedies and Review.Nature of Case: Whether a taxpayer can be precluded by summary judgement from disputing tax liability under section […]