Sean McNamee v. Commissioner

CourtUnited States Tax Court
DecidedMarch 18, 2020
StatusUnpublished

This text of Sean McNamee v. Commissioner (Sean McNamee v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sean McNamee v. Commissioner, (tax 2020).

Opinion

T.C. Memo. 2020-37

UNITED STATES TAX COURT

SEAN MCNAMEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 2458-19L. Filed March 18, 2020.

Robert S. Fink and Usman Mohammad, for petitioner.

Marissa J. Savit and Mimi M. Wong, for respondent.

MEMORANDUM OPINION

LAUBER, Judge: In this collection due process (CDP) case petitioner seeks

review pursuant to section 6330(d)(1)1 of a determination by the Internal Revenue

1 All statutory references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. We round all monetary amounts to the nearest dollar. -2-

[*2] Service (IRS or respondent) to uphold collection action. The IRS issued a

notice of intent to levy to facilitate collection of tax return preparer penalties

assessed against petitioner for 2009 and income tax liabilities he reported for

2010-2016. Petitioner does not challenge the collection action with respect to the

income tax liabilities, and respondent has abated (or agreed to abate) 19 of the 36

return preparer penalties. Remaining in dispute are 17 return preparer penalties

assessed under section 6694(a) for 2009, each in the amount of $1,000.

The parties have filed cross-motions for summary judgment under Rule 121.

We find no genuine dispute as to any material fact, and we agree with respond-

ent’s legal position with respect to the penalties that remain in dispute. We will

accordingly sustain the collection action to the extent set forth in this opinion.

Background

The following facts are based on the parties’ pleadings and motion papers,

including the attached declarations and exhibits. Petitioner resided in Connecticut

when he filed his petition.

A. Petitioner’s Underlying Tax Liabilities

1. Return Preparer Penalties

Petitioner is a certified public accountant who prepared income tax returns

for individual taxpayers. The IRS opened an examination to investigate the pro- -3-

[*3] priety of the returns he had prepared for (among other years) the taxable year

2009. On March 5, 2013, the IRS sent petitioner numerous Letters 1125, with en-

closed examination reports, explaining that it proposed to assess penalties with

respect to the returns he had prepared for 18 taxpayers for 2009. For each return

the IRS proposed to assess a $1,000 penalty under section 6694(a) (for “unreason-

able positions”) and an additional $4,000 penalty under section 6694(b) (for “will-

ful or reckless conduct”).

The Letters 1125, commonly called 30-day letters, informed petitioner that

he had the right to request a conference with the IRS Appeals Office and that the

deadline for filing a protest was April 4, 2013. The 30-day letters advised him

that, if he did not appeal, the IRS would assess the penalties and begin collection

action. Petitioner requested, and the examining agent granted, an extension of

time until April 19, 2013, to submit his protest.

The period of limitations on assessment of penalties under section 6694(a)

is three years after the filing of the return with respect to which the penalty is as-

sessed. Sec. 6696(d)(1). Because the penalties concerned returns for 2009, the

period of limitations for returns filed without extension was due to expire on or

about April 15, 2013. See sec. 6072(a). Concurrently with granting petitioner’s

request for additional time to file his protest, the examining agent sent him a -4-

[*4] Form 872-D, Consent to Extend the Time on Assessment of Tax Return

Preparer Penalty, asking that he agree to extend the limitations period to December

31, 2013. Petitioner declined to execute the Form 872-D.

Facing a limitations period nearing expiration, the examining agent assessed

the penalties. Between March 19 and April 15, 2013, the IRS assessed 17 penal-

ties under section 6694(a) and 17 penalties under section 6694(b). The IRS had

assessed two additional penalties previously, in December 2012. All 36 penalties

concerned returns filed for 2009.

Petitioner submitted by the extended due date a protest concerning the pen-

alties proposed, not only for 2009, but also for 2007, 2008, and 2010. In August

2013 petitioner’s protest was assigned to an Appeals officer (AO) in Buffalo, New

York. The AO believed that the penalties for 2008 might have been assessed after

the period of limitations had expired. After a discussion with her manager, the AO

decided to send the entire case back to the Examination Division. The case was

never returned to the AO, with the result that the Appeals Office never made a

“final administrative determination” regarding the return preparer penalties asses-

sed for 2009. See sec. 1.6694-4(a)(2), Income Tax Regs. -5-

[*5] 2. Individual Income Tax Liabilities

For tax years 2010-2016 petitioner filed Forms 1040, U.S. Individual In-

come Tax Return, reporting tax due for each year. His returns for 2010 and 2011

were filed late, but the returns for 2012-2016 were filed timely. Petitioner failed

to pay the full amounts of tax shown as due on these returns. For each year the

IRS assessed the tax shown as due plus applicable additions to tax. See secs.

6651(a)(1) and (2), 6654.

B. Collection Actions

1. Lien Notice and First CDP Hearing

In February 2014 the IRS issued petitioner a Letter 3172, Notice of Federal

Tax Lien Filing and Your Right to a Hearing (lien notice). The lien notice covered

petitioner’s unpaid preparer penalties for 2009 and his unpaid income tax liability

for 2011. He timely requested a CDP hearing. His case was assigned to a settle-

ment officer (SO1) in the IRS Appeals Office in Memphis, Tennessee.

In June 2014 SO1 held a telephone CDP conference with petitioner. Peti-

tioner contended that the 2009 penalties had been improperly assessed; SO1 re-

plied that she would need to do additional research. In July 2014, after consulting

her manager, SO1 informed petitioner of her view that liability challenges to re-

turn preparer penalties were not permitted during a CDP hearing. (Respondent has -6-

[*6] since conceded that this determination by SO1 was erroneous.) SO1

proceeded to close the case and on July 21, 2014, issued a notice of determination

sustaining the lien notice.

The notice of determination advised petitioner that, if he disagreed with

SO1’s action, he could file a petition with this Court within 30 days, i.e., by

August 20, 2014. See secs. 6320(c), 6330(d). Petitioner filed a petition on

January 5, 2015, more than four months late. The Court dismissed that case for

lack of jurisdiction. See McNamee v. Commissioner, T.C. Dkt. No. 104-15L

(order of dismissal dated May 29, 2015).

2. Levy Notice and Second CDP Hearing

As relevant here, petitioner’s unpaid liabilities (including interest) totaled

$265,661 as of March 2018: $106,602 for 36 preparer penalties assessed for 2009

and $159,059 for income tax liabilities assessed for 2010-2016. On March 5,

2018, an IRS collections officer hand delivered to petitioner a Letter 1058, Final

Notice of Intent to Levy and Notice of Your Right to a Hearing, covering these

liabilities. Petitioner timely requested a CDP hearing, contending that the section

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