Document Type

Article

Publication Date

5-2-2021

Abstract

Nature of Case: Whether the U.S. Tax Court has jurisdiction to decide Ms. Ruesch’s underlying liability for penalties assessed by the Internal Revenue Services (IRS); and whether Ms. Ruesch’s claim against the IRS is moot due to the IRS’s reversal of their classification of her as seriously delinquent?

The two important issues at dispute are: (1) whether the U.S. Tax Court has jurisdiction to decide Ms. Ruesch’s underlying liability for penalties assessed by the Internal Revenue Services (IRS); and (2) whether Ms. Ruesch’s claim against the IRS is moot due to the IRS’s reversal of their classification of her as seriously delinquent. This case sets forth the court’s jurisdiction over claims brought under I.R.C. section 7345 and how disputes are to be addressed when a claimant challenges their underlying liabilities for a penalty assessed by the IRS.

Comments

Vivian Ruesch v. Commissioner, 154 T.C. No. 13 (Jun. 25, 2020).

This post is also available online at: http://ggutaxreview.org/2021/05/02/ruesch-v-commr/

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