tax opinions

August 4, 2018

Norman v. United States – Court of Federal Claims Holds FBAR Willfulness Penalty Not Limited Contrary to Colliot District Court

Blogger’s Note:   It appears to me the trial-level judge in the Court of Federal Claims has determined the regulation at issue is invalid because it “conflicts” […]
August 4, 2018

Wadhan v. United States – Another District Court Opinion Following Colliot and Limiting FBAR Penalty

1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Chief Judge Marcia S. Krieger Civil Action No. 17-CV-1287-MSK UNITED STATES OF AMERICA, Plaintiffs, […]
May 30, 2018

United States v. Colliot, Defendant., U.S. District Court, W.D. Texas, 2018-1 U.S.T.C. ¶50,259, (May 16, 2018) – District Court Holds FBAR Penalty Limited

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS AUSTIN DIVISION UNITED STATES OF AMERICA, -vs- DOMINIQUE G. COLLIOT, Defendant. CAUSE NO.: AU-16-CA-01281-SS […]
February 26, 2018
Jersey Shore

What’s the Situation With “The Situation” of Jersey Shore?

  A blast from the past just came across the headlines recently surrounding a member of the hit show of 2009, Jersey Shore. I had previously […]
January 10, 2018

Post-Nuptial Planning: The Next Steps for Newly Married Couples

  The vows have been exchanged, the thank you cards have been sent, and the honeymoon is over …  Now, the real adventure begins.  Marriage is […]
May 1, 2017

Austin v. Commissioner, T.C. Memo. 2017-69

The Untied States Tax Court issued its opinion in Austin v. Commissioner, T.C. Memo. 2017-69, on April 24, 2017.  The full text of the opinion is […]
December 1, 2016

7th Circuit Court of Appeals Issues Ruling to Limit Tax Court Jurisdiction to Invalidate Levies

On November 18, the Seventh Circuit issued its opinion in Adolphson v. Commissioner, in which it upheld the ruling of Tax Court Judge Carluzzo in the […]
August 12, 2016

US Tax Court Sides With Whistleblower in Award Case

In June, the Tax Court issued its opinion in 21276-13W v. Commissioner, 144 T.C. No. 15 (2016).  This is one of the better written case opinions […]
December 20, 2015

Tax Court Issues Opinion in Sumner Redstone v. Commissioner, T.C. Memo. 2015-237

The United States Tax Court recently released its opinion in the Sumner Redstone case.  The case is notable not just because Redstone is a media magnate, […]
November 18, 2015

Tax Court Rejects Frivolous Filing Penalty for Taxpayer Invoking the Fifth Amendment in Tax Return

On November 6, 2015, the United States Tax Court issued its opinion in Youssefzadeh v. Commisioner, Docket No. 14868-14L, in which it held that the taxpayer […]