Wednesday, November 4, 2009

Ronald Davenport

I had to mention this case. I just had to.

I knew a Ronnie Davenport growing up. His brother, Tommy, was one of my contemporaries and best buddies. The Davenports I knew as a boy were all the most clever and interesting people. Ronnie, as I recall, was into short-wave radio, among other things. This was back before cell phones --- even before a lot of people had land-line telephones or TVs. I was always way impressed with Ronnie talking on that radio with people all around the world. It reminds me of the opening scene of the movie Contact. Of course Ronnie was no Jodie Foster and wasn't trying to contact a deceased parent. His parents were very much alive.

Anyway, the guy in this case couldn't be Ronnie from my boyhood. No way.

Ronald Davenport (of the case) faced the following proposals for more tax and penalties:

The Judge opined:

Petitioner is no stranger to the Court. The following is petitioner's history in this Court:

Well, I won't bore you with the details --- if you want them you can just read the opinion --- other than to say Ronnie did not cooperate with IRS and lost his case. He looks like the typical tax protestor, making silly, frivolous arguments that won't fly.

Tuesday, November 3, 2009

Two Tuesday Memo Decisions

The Tax Court issued two memorandum opinions today. One involves the determination that Linda Bruen was an innocent spouse, even though that terminology always seems like an oxymoron to me. The other one has to do with the nature of income from a cashed-in life insurance policy that the Barr couple received and the accuracy penalty the government said was attributable to them not properly reporting the nature of such incom.

Sunday, November 1, 2009

What's in a Name?

Peter M. Comensoli challenged the IRS in Tax Court. He was represented by Matthew S. DePerno. Alexandra E. Nicholaides represented the IRS. The IRS wanted to use its lien and levy powers to collect some taxes from Peter. Peter didn't want that to happen. The judge was named Goeke --- I didn't look up the rest of his name. Some of the players in the case were Paradym Group and A. Adonu Idahosa (makes me wonder what the "A." stands for). Symphony Financial Services was a player as was TCF Leasing, Inc. So was Back Porch Workout. Some of the action took place in Kalamazoo, Michigan.

I'm wreddyornot. Who are you?