T.C. Memo. 2020-50 UNITED STATES TAX COURT MELVIN COLLINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent NIKTA FATEMEH ABDOLRAHIM AND MELVIN COLLINS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 9649-14, 9650-14. Filed April 23, 2020. Melvin Collins and Nikta Fatemeh Abdolrahim, pro sese. Erika B. Cormier, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION ASHFORD, Judge: By statutory notice of deficiency dated January 23, 2014, respondent determined...
T.C. Memo. 2020-111 UNITED STATES TAX COURT JESUS R. OROPEZA AND FABIOLA ANAYA OROPEZA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9623-16. Filed July 21, 2020. Tim A. Tarter, Kacie N.C. Dillon, and Jonathan A. Halmi, for petitioners. Doreen M. Susi, John R. Gordon, John W. Stevens, and Michael R. Harrel, for respondent. MEMORANDUM OPINION LAUBER, Judge: This case is before the Court on the parties’ cross- motions for partial summary judgment on the question whether...
T.C. Memo. 2020-128 UNITED STATES TAX COURT JON DICKINSON AND HELEN DICKINSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9526-19. Filed September 3, 2020. Mitchell I. Horowitz and Qian Wang, for petitioners. Christopher D. Bradley and John T. Arthur, for respondent. MEMORANDUM OPINION GREAVES, Judge: This case is before the Court on petitioners’ motion for summary judgment and respondent’s cross-motion for partial summary judgment under Rule 121 (motions).1 In a...
T.C. Memo. 2020-77 UNITED STATES TAX COURT CHOONG H. KOH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9033-19. Filed June 4, 2020. Frank Agostino, for petitioner. Thomas A. Deamus, for respondent. MEMORANDUM OPINION GREAVES, Judge: This matter is before the Court on petitioner’s motion for judgment on the pleadings under Rule 120(a)1 (motion). Petitioner seeks 1 Unless otherwise noted, all Rule references are to the Tax Court Rules of Practice and Procedure, and all...
T.C. Memo. 2020-141 UNITED STATES TAX COURT JOHN WORTHINGTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 9026-19W. Filed October 8, 2020. P submitted to the Whistleblower Office (“WBO”) of the Internal Revenue Service (“IRS”) a claim on Form 211, “Application for Award for Original Information”, as later supplemented, alleging that an entity or operation of law enforcement agencies of cooperating counties (“T”) lacked status as a legal entity and therefore illegally...
T.C. Summary Opinion 2020-22 UNITED STATES TAX COURT ADAM JORDAN WINSLOW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8755-18S. Filed August 3, 2020. Adam Jordan Winslow, pro se. Timothy B. Heavner and Chelsey M. Pearson, for respondent. SUMMARY OPINION COLVIN, Judge: This case was heard pursuant to the provisions of section 74631 of the Internal Revenue Code in effect when the petition was filed. 1 Petitioner resided in North Carolina when he filed his petition....
T.C. Memo. 2020-10 UNITED STATES TAX COURT DANIEL ALAN NEAR AND DENISE FRANCES MAYHUGH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8721-18. Filed January 14, 2020. Daniel Alan Near, pro se. Daniel J. Kleid, Sharyn M. Ortega, and Brian A. Pfeifer, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION KERRIGAN, Judge: Respondent determined a deficiency of $8,721 and a penalty pursuant to section 6662(a) of $1,744 for 2015. Unless otherwise indicated, all section...
T.C. Memo. 2020-108 UNITED STATES TAX COURT EDWARD J. DUFFY AND SHANNON L. DUFFY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8711-16. Filed July 13, 2020. In 2009, Ps began renting out a property (Property 1) that they had previously used as a vacation home. In 2011, Ps sold Property 1. JPMC, a bank that held debt secured by the property, agreed to accept an amount of the sale proceeds less than the balance due in full satisfaction of the debt. In 2013, WF, another...
T.C. Memo. 2020-121 UNITED STATES TAX COURT NIRAV B. BABU, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent NIRAV BABU, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 8649-17, 20266-18.1 Filed August 17, 2020. Gerald W. Kelly, Jr., Daniel S. Heller, Vadim D. Ronzhes, Derek W. Kaczmarek, and David R. Jojola, for petitioner. Richard J. Hassebrock, Evan K. Like, and Gary R. Shuler, Jr., for respondent. 1 Nirav B. Babu and Nirav Babu are the same person. We...
T.C. Memo. 2020-42 UNITED STATES TAX COURT CHARLES P. LITTLEJOHN AND MAXINE M. LITTLEJOHN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8457-16. Filed April 9, 2020. John D. Faucher, for petitioners. Kris H. An, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: By notice of deficiency, respondent determined deficiencies in petitioners’ Federal income tax and section 6662(a) accuracy- related penalties as follows:1 1 All section references are to...
T.C. Memo 2020-42 UNITED STATES TAX COURT CHARLES P. LITTLEJOHN AND MAXINE M. LITTLEJOHN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8457-16. Filed April 9, 2020. John D. Faucher, for petitioners. Kris H. An, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION THORNTON, Judge: By notice of deficiency, respondent determined deficiencies in petitioners’ Federal income tax and section 6662(a) accuracy- related penalties as follows:1 1 All section references are to...
T.C. Memo. 2020-61 UNITED STATES TAX COURT JOCELYN B. NESBITT AND KEVIN NESBITT, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8296-19L. Filed May 18, 2020. Jocelyn B. Nesbitt and Kevin Nesbitt, pro sese. Stephen C. Welker and Bartholomew Cirenza, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case petitioners seek review pursuant to section 6330(d)(1)1 of the determination by the Internal Reve- 1 All statutory references are to...
T.C. Memo. 2020-106 UNITED STATES TAX COURT NORRIS A. DODSON AND HELEN M. DODSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7859-19L. Filed July 9, 2020. Norris A. Dodson and Helen M. Dodson, pro sese. Stephen C. Welker, Bartholomew Cirenza, and William J. Gregg, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case, petitioners seek review of a determination by the Internal Revenue Service (IRS or respon- dent) to uphold...
T.C. Memo. 2020-137 UNITED STATES TAX COURT GEORGE JEROME STEVENSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7471-19W. Filed September 30, 2020. George Jerome Stevenson, pro se. Elizabeth C. Mourges, Bartholomew Cirenza, and Nancy M. Gilmore, for respondent. MEMORANDUM OPINION LAUBER, Judge: This whistleblower award case is before the Court on a motion for summary judgment filed by the Internal Revenue Service (IRS or re- spondent). Respondent contends that the IRS...
T.C. Memo. 2020-72 UNITED STATES TAX COURT RONALD C. NIMMO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7441-19L. Filed June 1, 2020. Ronald C. Nimmo, pro se. Rachel L. Rollins and Jeffrey E. Gold, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case petitioner seeks review pursuant to sections 6320(c) and 6330(d)(1) of determinations by the Inter- nal Revenue Service (IRS or respondent) to sustain collection actions for his 2014-...
T.C. Memo. 2020-49 UNITED STATES TAX COURT PAULETTE ETOTY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6871-19L. Filed April 20, 2020. Paulette Etoty, pro se. Valerie Vlasenko and Thomas A. Deamus, for respondent. MEMORANDUM OPINION LAUBER, Judge: In this collection due process (CDP) case, petitioner seeks review of a determination by the Internal Revenue Service (IRS or respond- ent) that a levy on petitioner’s State income tax refund should not be sustained....
155 T.C. No. 5 UNITED STATES TAX COURT DOUGLAS M. THOMPSON AND LISA MAE THOMPSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6613-13. Filed August 31, 2020. R commenced an examination of returns filed by Ps. R’s revenue agent sent Ps letters offering to settle Ps’ tax liabilities associated with a certain transaction. Terms of the settlement offers required Ps to accept penalties calculated at reduced rates on any related underpayment that could later be determined....
T.C. Memo. 2020-97 UNITED STATES TAX COURT DUY DUC NGUYEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6602-17L. Filed June 30, 2020. Duy Duc Nguyen, pro se. Cameron W. Carr, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION PUGH, Judge: This case was commenced in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 63301 1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as...
T.C. Memo. 2020-52 UNITED STATES TAX COURT RICHMOND PATIENTS GROUP, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6504-18. Filed May 4, 2020. Jeffrey B. Kahn, for petitioner. Cameron W. Carr, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION KERRIGAN, Judge: In a notice of deficiency dated January 17, 2018, respondent determined Richmond Patients Group (Richmond) had deficiencies of $681,679 and $908,855 and was liable for accuracy-related penalties pursuant to...
