Tom Gonzales
United States Tax Court · 2025-10-08
This U.S. Tax Court case involved petitioner Tom Gonzales challenging the timeliness of three affected items Notices of Deficiency issued by the IRS in 2018 for tax years 2000, 2001, and 2003, which stemmed from disallowed losses claimed through a partnership entity (Logan) involved in a Son-of-BOSS transaction. The court considered the respondent's motion for partial summary judgment on whether these notices were issued within the statutory assessment periods under sections 6501 and 6229. The court granted the motion, holding that the notices were timely because the limitations period had been suspended by the related partnership-level TEFRA proceeding, which became final in February 2018 upon denial of certiorari, with the notices mailed later that year within the allowable one-year window after finality. The court rejected arguments that an earlier individual deficiency case (Gonzales I) affected the timeline, noting it was separate from the partnership proceeding that determined the FPAA's timeliness.
taxesprocedure
Jordan John O'Neill
United States Tax Court · 2025-05-20
This U.S. Tax Court case involved petitioner Jordan John O'Neill's challenge to two Notices of Deficiency issued by the IRS for tax years 2016 and 2017, along with a related collection action notice. The parties filed cross-motions to dismiss for lack of jurisdiction, with the petitioner arguing the notices were invalid due to improper mailing and issuance by an official lacking delegated authority, and the respondent arguing the petition was untimely. After an evidentiary hearing, the court denied the petitioner's motion and granted the respondent's motion, dismissing the case. The core reasoning was that the petition was filed more than 900 days after the notices were mailed—well beyond the 90-day jurisdictional deadline under section 6213(a)—and that the IRS had sufficiently proven proper mailing via USPS records while the authority argument lacked merit.
taxesprocedure
Bruce Edward Johnson
United States Tax Court · 2024-10-17
This case involved a whistleblower award claim under Internal Revenue Code section 7623(b), in which petitioner Bruce Edward Johnson challenged the IRS Whistleblower Office's denial of an award after he reported that a tax-exempt entertainment and hospitality organization was improperly operating commercial activities and owed over $40 million in unrelated business income tax for certain years. The IRS examined the target for later tax years, proposed about $1.4 million in adjustments based on the whistleblower's information, but the Independent Office of Appeals reversed those adjustments in full, resulting in no additional tax collected. The Tax Court granted the IRS's motion for summary judgment and sustained the denial, holding that an award requires both the initiation of an administrative action and the actual collection of tax proceeds, which did not occur here. The court noted it lacked authority to review the underlying tax liability determination or compel further IRS action. Petitioner resided in Iowa and proceeded pro se.
taxesprocedure
Maria Isabel Goode, and James T. Goode, Jr., Intervenor
United States Tax Court · 2021-09-23
This case involves Maria Isabel Goode petitioning the Tax Court for review of the IRS determination denying her relief from joint and several liability on a 2010 joint federal income tax return filed with her former spouse under IRC section 6015(f). The underlying tax liability arose from unreported payments on defaulted Thrift Savings Plan loans that were treated as deemed distributions. The court held that the petitioner does not qualify for equitable relief. Its reasoning centered on the knowledge factor weighing heavily against relief, as she knew of the unpaid balance due when signing the return and had consented to the loans, outweighing other factors such as her lack of significant benefit from the underpayment and post-divorce tax compliance.
taxesfamily law
Avito M. Vasquez
United States Tax Court · 2021-09-13
The case involved Avito M. Vasquez challenging the IRS's disallowance of miscellaneous itemized deductions for unreimbursed employee business expenses on his 2015 tax return, including mileage, meals, and other costs related to his work as an electrician in the oil and gas industry. The Tax Court held that Vasquez was not entitled to deductions for most of these expenses, sustaining the IRS's determination except for a partial allowance on cell phone expenses. The court's reasoning centered on the failure to meet substantiation requirements for travel and mileage expenses under tax code sections like 274(d), the abandonment of claims for meals, and the determination that only half of the cell phone use was business-related and thus deductible while the rest was personal.
taxesbusiness & regulatory
Earl R. Detwiler & Diana M. Detwiler
United States Tax Court · 2021-08-17
This U.S. Tax Court case involved petitioners Earl R. Detwiler and Diana M. Detwiler, who challenged the IRS's disallowance of portions of their claimed deductions on their 2015 tax return. After concessions, the court addressed whether they could deduct $7,170 in unreimbursed employee business expenses (including mileage, travel, meals, and other costs related to petitioner husband's work as a chaplain) and $38,104 in medical expenses. The court held that petitioners were not entitled to deductions beyond the amounts the IRS had allowed. The core reasoning was that taxpayers bear the burden of substantiating deductions with adequate records, and petitioners failed to provide sufficient documentation of business purpose, dates, locations, or payee details as required by sections 274(d) and 213 and related regulations; estimates under the Cohan rule were also unavailable due to lack of a reasonable basis and strict substantiation rules.
taxes