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Fortune smiled on Robert S. Clark: He had “an auto body shop, rental properties, a large home, and numerous trucks, automobiles, and utility vehicles.” Clark v. Comm’r,  T.C. Memo 2021-114, 2021 Tax Ct. Memo LEXIS 148 at **1 (Sept. 28,

Even when the stakes are substantial, taxpayers do not
always give refund claims the careful consideration that they deserve.

The taxpayer must exhaust his/her administrative remedies:

No suit or proceeding shall be maintained in any court for the recovery of

Organizations that are exempt from income tax under section 501(c)(3) of the Internal Revenue Code are supposed to be “organized and operated exclusively for religious, charitable, scientific, testing for public safety, literary, or educational purposes.” I.R.C. § 501(c)(3). Historically, when