TaxProf Blog – Bryan Camp: Lesson From The Tax Court: Abatement Of Assessment Brings No Relief From Liability (April 26, 2021)

Bryan Camp has published an article on the TaxProf Blog, titled “Lesson From The Tax Court: Abatement Of Assessment Brings No Relief From Liability,” which discusses the outcomes of Robert Craig Colton and Alina Mazwin v Commissioner, T.C. Memo. 2021-44 (Apr. 21, 2021) (Judge Lauber) as they pertain to differences between tax assessment and tax liability. The article begins as follows:

Letters from the IRS are often confusing, both to clients and to practitioners.  So when the taxpayers in Robert Craig Colton and Alina Mazwin v Commissioner, T.C. Memo. 2021-44 (Apr. 21, 2021) (Judge Lauber) received a letter from the IRS saying “you do not owe us any money” for the very year they were disputing in Tax Court, you would not blame them for thinking that the IRS had conceded the case.  It hadn’t.  The letter was only telling them that a premature assessment of the deficiency had been abated, not that the IRS’s judgment about the underlying liability had changed.  The case teaches the important lesson that assessment and liability are different.  One must always be aware of the distinction between an assessment (or abatement) and the underlying liability.  Details below the fold.

To download the full opinion, click here: Robert Craig Colton and Alina Mazwin v Commissioner, T.C. Memo. 2021-44 (Apr. 21, 2021)

To see the full article, click here: “Lesson From The Tax Court: Abatement Of Assessment Brings No Relief From Liability”

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