Tax Court in Brief | Larochelle and Larochelle v. Commissioner, T.C. Summary Opinion 2022-12 | July 12, 2022 | Leyden | Dkt. 10416-20S

Share this Article
Facebook Icon LinkedIn Icon Twitter Icon

Freeman Law is a tax, white-collar, and litigation boutique law firm. We offer unique and valued counsel, insight, and experience. Our firm is where clients turn when the stakes are high and the issues are complex.

The Tax Court in Brief – July 11th – July 15th, 2022

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

For a link to our podcast covering the Tax Court in Brief, download here or check out other episodes of The Freeman Law Project.

Tax Litigation:  The Week of July 11th, 2022, through July 15th, 2022

Larochelle and Larochelle v. Commissioner, T.C. Summary Opinion 2022-12 | July 12, 2022 | Leyden | Dkt. 10416-20S

Short Summary:

The IRS found a deficiency in the Petitioners’ tax return and issued a notice of deficiency. Petitioners filed for a redetermination pursuant to IRC Section 6213(a). Ultimately, they conceded the deficiency and challenged only an accuracy-related penalty of approximately $10,000.00.

To prepare their returns, Petitioners did nothing more than provide documents to their tax professional. Between their two residences, the Petitioners’ lost a Form 1099-R for a $238,000 distribution from an IRA. This income went unreported and led to a CP2000 notice to which Petitioners did not respond. After receiving a notice of deficiency, Petitioners paid the deficiency in full an requested the abatement of an accuracy-related penalty. The IRS denied the request.

Key Issues:

Primary Holdings:

Key Points of Law

Insights