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Tax Court News & Case Summaries

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newsUS Tax Court

Algarawi and Hachim v. Commissioner: Unreported Income and Accuracy-Related Penalties Upheld

S. 60 in accuracy-related penalties for tax years 2020 and 2021.

Docket No. 6824-24
newsUS Tax Court

Zulfiqar v. Commissioner: Stipulated Decisions and the Scope of Tax Court Jurisdiction in CDP Hearings

The stakes in Muhammad Zulfiqar and Shazia Zulfiqar v.

Docket Nos. 20538-23L, 1998-24L
newsUS Tax Court

Asia Zaheen v. Commissioner of Internal Revenue: Abuse and Financial Control Justify Innocent Spouse Relief

The stakes were nothing short of life-altering for Dr. Asia Zaheen: a $120,510 tax deficiency and an additional $24,102 penalty for tax year 2019, all stemming from a joint return she signed with her then-spouse, Kamran Ehsan.

13863-22
newsUS Tax Court

Vincent J. Fumo v. Commissioner of Internal Revenue

The stakes could not have been higher. S. Tax Court issued its September 24, 2025 opinion in Fumo v. Commissioner, it delivered a verdict that would cost former Pennsylvania Senator Vincent J. 5 million in unreported income, fraud penalties, and excise taxes.

Docket Nos. 17603-13, 17614-13
newsUS Tax Court

Whistleblower Denied Award Despite Alleged Taxpayer Behavior Change

The stakes couldn’t have been higher. A whistleblower came forward with explosive allegations of a $1 billion tax evasion scheme, claiming the IRS was owed $400 million in unpaid taxes.

11099-13W
newsUS Tax Court

Walker v. Commissioner: IRS Must Issue Notice of Deficiency for Premium Tax Credit Adjustments

The stakes couldn’t have been higher: $20,904 in disputed tax liability hinged on whether the IRS could bypass a fundamental safeguard in the tax code. S.

2801-24L
newsUS Tax Court

Dunn v. Commissioner: Tax Court Grants Dismissal Without Prejudice in CDP Case Post-Boechler

The Tax Court’s January 7, 2026 ruling in Dunn v. C. Memo. 2026-2) exposes a harsh reality for taxpayers navigating Collection Due Process (CDP) hearings: a procedural misstep can erase all leverage, even when no tax is owed.

5294-25L
newsUS Tax Court

Crawford v. Commissioner: Trust Fund Recovery Penalty and Collection Due Process Dispute

The stakes couldn’t have been higher when Todd A. Crawford, a small-business owner, found himself staring down a $28,977 Trust Fund Recovery Penalty (TFRP) liability for unpaid payroll taxes.

8081-23L
newsUS Tax Court

Milk Saving Starving Children Foundation v. Commissioner of Internal Revenue

The stakes couldn’t have been clearer: the IRS revoked the Milk Saving Starving Children Foundation’s 501(c)(3) tax-exempt status effective July 1, 2017, leaving the foundation liable for $26,447 in unrelated business income tax for 2018; with no charitable expenditures to offset it.

13274-22X
newsUS Tax Court

Tax Court Denies $188,563 Charitable Deduction for Lack of Substantiation

S. Tax Court delivered a stark reminder to high-net-worth taxpayers this week, denying a $188,563 charitable deduction claimed by Luke and Breeana Gibson for donated "high-end cycling apparel" due to a complete failure to substantiate the donation’s basis and fair market value.

17305-23S
newsUS Tax Court

Estate of Georgia M. Spenlinhauer v. Commissioner: A $5 Million Estate Tax Dispute Over Late Elections, Valuation, and Transferee Liability

The Tax Court’s December 30, 2025 ruling in Estate of Georgia M. Spenlinhauer delivers a stark warning to executors and heirs: missed deadlines and overlooked elections can trigger millions in unpaid taxes, penalties, and transferee liability. 5 million at stake.

Docket Nos. 4998-18, 11286-18
newsUS Tax Court

Carl B. Barney v. Commissioner of Internal Revenue: The $31 Million Bargain Sale Dispute

9 million refund demand. At issue is whether Carl Barney’s transfer of his for-profit college empire to a nonprofit entity in 2012 was a legitimate bargain sale under Section 170; the charitable contribution deduction statute; or a disguised sale designed to avoid capital gains tax.

5310-22
newsUS Tax Court

Montes and Yanez v. Commissioner: Qualifying Child Residency Requirement Dispute

The stakes could not have been higher for Ignacio Montes Gonzalez and Adalberto Yanez Alvarenga when the Tax Court delivered its final ruling in their case.

4951-23
newsUS Tax Court

Fussell v. Commissioner: Tax Court Rejects $420K Bad Debt Deduction for Purported Loans to Failed Startup

The Tax Court’s December 18, 2025 ruling in Mark L. Fussell v. Commissioner delivers a stark warning to taxpayers who attempt to deduct loans to failed businesses as bad debts.

9700-23
newsUS Tax Court

Tax Court Upholds IRS Rejection of Marijuana Dispensary’s $65K Offer-in-Compromise, Citing § 280E Consistency

The Tax Court’s December 16, 2025 ruling in Mission Organic Center, Inc. v. Commissioner delivered a stark warning to state-legal marijuana businesses: the IRS’s collection power trumps even the most aggressive settlement offers when nondeductible §280E expenses are involved.

Docket Nos. 6937-23L, 6938-23L
newsUS Tax Court

Riddle Aggregates, LLC v. Commissioner: Seventh Amendment Does Not Apply to TEFRA Partnership-Level Accuracy-Related Penalties

The stakes could not have been higher when the Tax Court denied a motion to dismiss a $45 million dispute over a conservation easement deduction; one that, if allowed, would have erased nearly $45 million in claimed charitable contributions, plus a 20% accuracy-related penalty...

31104-21