Special Courts Case Commentaries

Jurisdictional Boundaries in Deficiency Petitions: Hallmark Research Collective v. Commissioner of Internal Revenue

Date: Nov 30, 2022

Jurisdictional Boundaries in Deficiency Petitions: Hallmark Research Collective v. Commissioner of Internal Revenue Introduction The case of Hallmark Research Collective v. Commissioner of Internal...

Limitations on Tax Court Jurisdiction Over Overpayments in Section 6330 Proceedings: Greene-Thapedi v. Commissioner

Date: Jan 13, 2006

Limitations on Tax Court Jurisdiction Over Overpayments in Section 6330 Proceedings Introduction In the landmark case Llwellyn Greene–Thapedi v. Commissioner of Internal Revenue, 126 T.C. 1 (2006),...

Affirmation of IRS's Discretion in Levy Proceedings: Murphy v. Commissioner

Date: Dec 30, 2005

Affirmation of IRS's Discretion in Levy Proceedings: Murphy v. Commissioner Introduction Murphy v. Commissioner of Internal Revenue (125 T.C. 301, 2005) is a pivotal case adjudicated by the United...

Dismissal Without Prejudice for Section 6320(c) Petitions: Wagner v. Commissioner

Date: Apr 16, 2002

Dismissal Without Prejudice for Section 6320(c) Petitions: Wagner v. Commissioner Introduction In the case of Richard T. Wagner and Margie Wagner v. Commissioner of Internal Revenue (No. 7186–00L,...

Shifting Burden of Proof Under IRC Section 7491: Insights from Higbee v. Commissioner

Date: Jun 7, 2001

Shifting Burden of Proof Under IRC Section 7491: Insights from Higbee v. Commissioner Introduction The Tax Court case of Earl G. Higbee and Lesley A. Higbee v. Commissioner of Internal Revenue, 116...

Burden of Proof in Tax Litigation: Insights from Higbee v. Commissioner under IRC §7491

Date: Jun 7, 2001

Burden of Proof in Tax Litigation: Insights from Higbee v. Commissioner under IRC §7491 Introduction Earl G. Higbee and Lesley A. Higbee v. Commissioner of Internal Revenue is a pivotal case...

Enhancements to Multidistrict Litigation Procedures: Comprehensive Analysis

Date: Apr 3, 2001

Enhancements to Multidistrict Litigation Procedures: Comprehensive Analysis Introduction On April 2, 2001, the Judicial Panel on Multidistrict Litigation (JPML) issued an Order adopting substantial...

Affirmation of IRS Appeals Procedures in Davis v. Commissioner: Form 4340 Reliance, Hearing Limitations, and Section 6065 Exemption

Date: Aug 1, 2000

Affirmation of IRS Appeals Procedures in Davis v. Commissioner: Form 4340 Reliance, Hearing Limitations, and Section 6065 Exemption Introduction In the landmark case of Ronald A. Davis v....

Tax Court Limits VEBA Contribution Deductions to Term Life Insurance Costs and Recognizes Excess as Constructive Dividends

Date: Aug 1, 2000

Tax Court Limits VEBA Contribution Deductions to Term Life Insurance Costs and Recognizes Excess as Constructive Dividends Introduction The case of Neonatology Associates, P.A., et al. v....

Preclusion of Tax Liability Challenges Under IRC §6330(c)(2)(B): Sego v. Commissioner

Date: Jul 1, 2000

Preclusion of Tax Liability Challenges Under IRC §6330(c)(2)(B): Sego v. Commissioner Introduction In Steven and Davina Sego v. Commissioner of Internal Revenue (114 T.C. 604, 2000), the United...

Jurisdictional Limits in Collection Due Process: Offiler v. Commissioner of Internal Revenue

Date: Jun 20, 2000

Jurisdictional Limits in Collection Due Process: Offiler v. Commissioner of Internal Revenue (114 T.C. 492) Introduction Lucielle J. Offiler, a taxpayer residing in Kissimmee, Florida, filed a...

Limitations on Contesting Underlying Tax Liability in Pre-Levy Hearings: Goza v. Commissioner of IRS

Date: Mar 18, 2000

Limitations on Contesting Underlying Tax Liability in Pre-Levy Hearings: Goza v. Commissioner of Internal Revenue Introduction Howard Goza v. Commissioner of Internal Revenue, 114 T.C. 176 (2000), is...

Strict Adherence to Deficiency Petition Process Under IRC Section 6330: Howard Goza v. Commissioner of Internal Revenue

Date: Mar 18, 2000

Strict Adherence to Deficiency Petition Process Under IRC Section 6330: Howard Goza v. Commissioner of Internal Revenue Introduction The case of Howard Goza v. Commissioner of Internal Revenue,...

Romann v. Commissioner: Defining "Interested Party" in Declaratory Judgment Actions

Date: Nov 5, 1998

Romann v. Commissioner: Defining "Interested Party" in Declaratory Judgment Actions 1. Introduction Romann v. Commissioner is a pivotal case adjudicated by the United States Tax Court on November 4,...

Sundstrand v. Commissioner: Payments for Cost Accounting Violations Not Covered by IRC Section 1481

Date: May 5, 1992

Sundstrand v. Commissioner: Payments for Cost Accounting Violations Not Covered by IRC Section 1481 Introduction The case of Sundstrand Corporation and Consolidated Subsidiaries v. Commissioner of...

Repayments Under Settlement Agreements Excluded from Section 1481 Renegotiation Provisions

Date: May 5, 1992

Repayments Under Settlement Agreements Excluded from Section 1481 Renegotiation Provisions Introduction In the case of Sundstrand Corporation and Consolidated Subsidiaries v. Commissioner of Internal...

Centralization of Asbestos Litigation under 28 U.S.C. § 1407: A Landmark Decision

Date: Jul 30, 1991

Centralization of Asbestos Litigation under 28 U.S.C. § 1407: A Landmark Decision Introduction The judicial landscape for asbestos-related litigation underwent a significant transformation with the...

Notice of Deficiency: Jurisdictional Implications in Monge v. Commissioner

Date: Jul 13, 1989

Notice of Deficiency: Jurisdictional Implications in Monge v. Commissioner Introduction Monge v. Commissioner is a pivotal case adjudicated by the United States Tax Court on July 12, 1989 (Docket No....

Res Judicata in Federal Tax Litigation: Florida Peach Corp. v. Commissioner

Date: Apr 13, 1988

Res Judicata in Federal Tax Litigation: Florida Peach Corp. v. Commissioner Introduction Florida Peach Corporation v. Commissioner of Internal Revenue, 90 T.C. 678 (1988), is a seminal case in the...

Establishing Jurisdictional Boundaries in Multi-Entity Tax Deficiency Cases: Normac, Inc. v. Commissioner

Date: Jan 27, 1988

Establishing Jurisdictional Boundaries in Multi-Entity Tax Deficiency Cases: Normac, Inc. and Normac International, Limited v. Commissioner Introduction The case of Normac, Incorporated, and Normac...