Abstract Case Name: Schieber v. Commissioner of Internal Revenue, T.C. Memo, T.C. Memo 2017-32 (Feb 9, 2017)Jurisdiction: U.S.T.C.Petitioner: David W. Schieber and Janet L. Schieber Respondent: Commissioner of the Internal Revenue Service.Concepts: Bankruptcy; Defined Benefit Plan; Cancellation of DebtNature of Case: Whether a defined benefit plan is an asset when determining insolvency for the purposes of cancellation of […]
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 […]
Abstract Case Name: Laidlaw’s Harley Davidson Sales, Inc. v. Commissioner, 154 T.C. 68 (Jan. 16, 2020).Jurisdiction: U.S.T.C.Petitioner: Laidlaw’s Harley Davidson Sales, Inc.Respondent: Commissioner of the Internal Revenue Service.Concepts: IRS Examinations; Civil Tax Penalties; Penalty Procedures; Collections Due Process.Nature of Case: Whether an IRS agent proposing a penalty under I.R.C. § 6707A for failure to disclose participation in […]
Abstract Case Name: Near v. Commissioner, T.C. Memo 2020-010 (January 14, 2020).Jurisdiction: U.S.T.C.Petitioners: Daniel Alan Near and Denise Frances Mayhugh.Respondent: Commissioner of the Internal Revenue Service.Concepts: Schedule C, Profit or Loss from Business; Tax Deduction; Travel and Car and Truck Expenses; Accuracy Related PenaltyNature of Case: Whether petitioners are entitled to deduct travel and car and truck […]