Vincent J. Liuzza, Jr. served as the bankruptcy trustee for Texas Pig Stands, a venerable San Antonio, Texas, restaurant company. In an attempt to keep the restaurants afloat after a plan of reorganization had been confirmed, Liuzza failed to remit state sales taxes to the Texas Comptroller. The iss...
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Defendant-appellant Gary Woltmann pled guilty in the United States District Court for the Eastern District of New York (Platt, J.) to one count of tax fraud. Woltmann filed a notice of appeal challenging the sentence, and the government countered with a motion to dismiss, citing Woltmann’s waiver ...
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By one statutory notice dated March 21, 2008, respondent determined deficiencies of $16,873 and $17,537 with respect to Huda T. Scheidelman’s (petitioner’s) Federal income taxes for 2004 and 2005, respectively. Respondent also determined section 6662(a) penalties of $3,374.60 and $3,507.40 for 2...
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This section 6015(e) case was heard pursuant to the provisions of section 7463. Pursuant to section 7463(b), the decision to be entered is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case.
In a final notice of determination dated June 9, 200...
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Respondent determined a deficiency in petitioner’s Federal income tax of $8,153 for 2003, a failure to file addition to tax pursuant to section 6651(a)(1) of $1,780, and an accuracy-related penalty pursuant to section 6662(a) of $1,631. The issues remaining to be decided relate to petitioner’s e...
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Under Oklahoma law, “[a]ll unstamped cigarettes . . . found in the possession . . . of any person, for the purpose of being . . . transported from one place to another in this state, for the purpose of evading . . . the provisions of [the Cigarette Stamp Tax Act] . . . may be seized by any authori...
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Section 7407 of Title 26 of the United States Code permits the United States to seek, and a district court to issue, an injunction prohibiting tax preparers from engaging in certain deceptive or fraudulent practices. 26 U.S.C. § 7407. The district court may specifically enjoin a tax preparer from e...
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Plaintiff Sean M. Liu has filed suit against the United States for the return of income tax under 26 U.S.C. § 6511(a), (d)(3). Defendant United States (“the Government”) now moves the Court, pursuant to Rule 12(b)(1) of the Rules of the Court of Federal Claims (“RCFC”), to dismiss this acti...
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This case was commenced in response to notices of determination concerning collection action sustaining the filing of a Federal tax lien and a notice of intent to levy with respect to civil penalties, additions to tax, and income tax deficiencies due from petitioner for periods from 1996 to 2002. Ea...
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Respondent determined deficiencies in petitioners’ Federal income tax and additions to tax pursuant to sections 6651(a)(1) and (2) and 6654(a)2 for their 2000, 2001, and 2002 tax years in the following amounts: